Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 1 of 414 PagelD #: 767 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -X DEBORAH ABEEL, DONNA DILLS, FRANCIS TALBOT, GARY VALIERE, ROBERT ROCKWOOD, DOUG SCHMIDT, DAVE SCHMIDT, DALE SCHMIDT, RICK ADAMS, ROBERT AKASHI, JIMMY ALAURIA, DEBBIE EDITH ALEGRIA, IZAIDA ALTAMIRANO, ROBERTA ALVAREZ, PATRICIA ALVERT, FATIMA APONTE, MANUEL ARECHIGA JR, SCOTT ARMSTRONG, LAURA AUPPERLE, JOSE P. AYALA, ALEX BACARON, WILLIAM BARBER, PHILIP BARR, FRANCISCO BARRIOS, TOM BEINAR, ANDREW BELCHER, MIRTHA BERNES, NASSARBEY, MARK BLANCO, JOHN BOBEK, ELINOR BOZZONE, LAWRENCE BRACCO, NATHAN BREHM, KIM BRIDGES, MIKE BRIGGS, ERENSTINE BRINKLEY, VICKIE BROCK, DEXTER BROWN, DIANE BROWN, LINDA BURGER, BONNIE BUTTERWORTH, JESSICA CABASAL, CARLA CALER, PAUL CAMPAGNA, HARRY CAMPBELL, IRENE CARDENAS, MARIA CARINO, JON CARLSON, DINORAH CARMENATE, JUAN CARRILLO, JAQUELINE CARROLL, JOSE Z. CASTRO, PAUL CATER, ELOY CERTEZA, GEOFFREY CHARLTON, MARK CHASTEEN, VIPIN CHATURVEDI, RAQUEL CHAVEZ, RITO CHAVEZ, ANTONIO CHAVEZ, KEVIN CHEEK, WILLIAM CHIN, MEHRDAD CHITSAZ, HECTOR CIBRIAN, RENATA CIRCEO, ELIZABETH CLAMPET, STEPHEN CLARKE, CHRISTOPHER COCKRELL, DANIELLE COCKRELL, GEOFFREY COCKRELL, LUISE COHEN, OLGA L. COLLAZO, ROLANDO COLLAZO, ARTEMIO CONCEPCION, KAT CONWAY, RUTH CORONA, LUIS COSIO, PATRICIA CRESPO, MARGOCRUZ, MARIA CRUZ, OCTAVIO CRUZ, WILLIAM CUBIAS, JOSE CUESTA, DONNA DALTON, MARIA DE LA PAZ JIMENEZ, LOURDES RUIZ DE LA TORRE, CELON D. DENNIS, DOUGLAS DENT, CHRISTIAN DIAZ, MARTHA DIAZ, NICHOLAS DIETEL, JEFFREY DIXON, IRA DORFMAN, PATRICIA DOWLING, DANIEL DWYER, JAMES EBLEN, GLEN ENG, PATRICIA ESPINOSA, ALICIA FAJARDO, CLOVIS FEARON, ALBERTINA FIGUEROA, ROBERTO FIGUEROA, JOSEPH FITZGERALD, CAROL FLEMMING, COREY FLINN, LEONARDO FLORES, ALAN FOGELSTROM, NORMA FOGELSTROM, DONNA FOOTE, JULIE FRALEY, DENNIS FROST, CHRISTOPHE FRUCTUS, SUSAN GALLAGHER, LIDIA GARCIA, SIMONA GARCIA, JOE GARCIA, TRACIGEHM, PHILLIP GENOVESE, BARBARA GIBBS, JAMES GILBERT, BRADLEY GIPOLAN, DENNIS GLEASON, TOMMY GLOVER, CARLOS GONZALES, MARIA GONZALES, NELSON A. GONZALEZ, NELSON J. GONZALEZ, CHRISTOPHER GROSSMAN, DIANE GRUBIC, WALTER GRUB IC, NESTOR GUILLEN, WILLIAM GUTIERREZ, ENRIQUE No. 12-cv-04269-JBW-RML [Assigned to: Senior Judge Jack B. Weinstein] [Referred to: Magistrate Judge Robert M. Levy] VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF [JURY TRIAL DEMANDED] Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 2 of 414 PagelD #: 768 GUZMAN, MAGA GUZMAN, MARIA GUZMAN, ALLISON HANSON, JOHN HANSON, THOMAS HERBST, JORGE L. HERNANDEZ, MARCELLA HERNANDEZ, MIGUEL HERNANDEZ, DAVID HERRON, SESSING HEWITT, LISA HIGGENS, NANCY HOLCOMBE, VIRGINIA HOSKING, VINCE HUBBARD, KELVIN HURDLE, MICHELLE HURTADO, ART ITURBE, ATHENA JACKSON, MARIA DE LA PAZ JIMENEZ, HARLENE JOHNSON, PORTIA JOSEPH, JEROME KAMINS, JENNIFER KAUER, DAN KLEIN, NANCY KRANTZ, MORGAN LAWLEY, BOBBIE LEONARD, MARK C. LILLY, MIROSLAVA LITTERDRAGT, DOUGLAS LIZARDI, DINORAH LLANES, ROSALINDA LOCKHART, THOMAS LOCKHART, ALAN LOCKLEAR, MARIA DOLORES LOMBERA, MOISES LOPEZ, ANGEL LOPEZ, MOISES LOPEZ, DELORES LUCAS, BURT LUND, MAE LUND, ALEJANDRO LUZARDO, RONNIE LYLES, BRYAN LYNCH, JOSEPH K LYONS, BRUCE MACBRIDE, ANITA MACHADO, TANYA MACHADO, STELLA MARKLEY, TERESA MARQUEZ, LUIS MARTINEZ, PATRICK MARTINEZ, CHARLOTTE MCARDLE, SAOVANNI MEAS, DANIEL MELENDEZ, GLORIA MELO, MARGARITA MILAM, MARIE MILLER, AARON MIR, ARLYNMIR, JASON MOEDING, VERONICA MONTERRUBIO, ERIK MUMFORD, ANTONIO MUNOZ, CARMEN MUNOZ, CINDY MURRILLO, JUAN CARLOS MURRILLO, JOE NAVARRO, CRISTINA NAVARRO, MICAH NEELY, RICHARD NEELY, JONIQUE GARCIA, ERNESTO NEPOMUCENO, CATHERINE NUTT, SENEN OCHOA, TALIA OLIVERA, CHRISTINA ORNELAS, KAROL OUSLEY, FRANK PACHECO, ARMANDO PADILLA, ANGELA PARADA, RUBEN PARRA, EUGENE PATERRA, ALTIN A PATRICK, ROLAND PERKINS, RAUL PERNETT, MICHAEL PHILLIPS, LESLIE POLLACK, THOMAS POUPARD, CARTER POWELL, MERY QUINT ANA, MERLE RAGAN, DANIEL RAMIREZ, FRANCISCO RAMIREZ, ANGELICA RAMIREZ, KAIVALYA RAWAL, JOE REJD, SILVIA RENDON, JOSE REYES, MICHAEL RICCIARDI, MARJORIE RICHARDSON, DAVE RICHMAN, CONNIE RICOTTA, EDDIE RIVERA, GARY ROBERTS, HERMELINDO ROCHA - VARGAS, GUIDO RODRIGUEZ, MARTHA RODRIGUEZ, NANCY P. RODRIGUEZ, PAUL RODRIGUEZ, ENRIQUE ROMERO, MICHAEL ROMERO, SHERRIE SAFKO, LILY S ALAS, GUADALUPE SANCHEZ, HILDA SANCHEZ, JAIME SANCHEZ, ROGER SANCHEZ, ANTONIO SANCHEZ, HECTOR SANCHEZ, MARIA SANCHEZ, SUSAN SANDERS, RUBEN SANTIAGO, JOSE SAUCEDO, VICKIE SCHETRITT, ROBERT SCHMALFELDT, JOSE ALFREDO SEGOVIA, SHERYL SEIM-MONTOYA, ARVIN SERRANO, MARGARITA SHEA, KENNETH SIMONSEN, CHARLES SMITH, CRAYTON SMITH, ROBERT SMITH, ZENAIDA SMITH, JAMES SNYDER, VALORIE SNYDER, ILIANA SORENSEN, ROSARIO MARIA SOTO, DAVID STARKEY, DEL STAUDINGER, ANDREW STOLZ, PAUL - 2 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 3 of 414 PagelD #: 769 STROHECKER, RICHARD STRUNK, LIDIA TAPIA, DELANETARRA, MANUEL TAVARES, MARIA TAVARES, ROBERT TAYLOR, JOHN TEDESCO, EVA THIELK, JOSATIRADO, MAILIN TOMLINSON, TONY TRUJILLO, JODITUFT, JEFF TURNER, MALCOLM TURNER, RITAUCHEKA, HUGO URRIBARRI, MITCH VANMECHELEN, HERMELINDO VARGAS, THEREISI VILLARUZ, DONALD VITAK II, MARGUERITE VITA- MATUZOLA, GARYWAGGY, CARROLL WALTERS, ARTHUR WEAVER JR., TRACY WEBER, KENNETH WEINER, GUNTER WEISSMANN, CLINT WEST, NIKKI WHITE, ACHINI WHITE, MICHAEL WIEDERHOLD, GEORGE WILCOX, PAUL WILDER, DEBRA WILSON, JONWJTHROW, PETER WRIGHT, PHILIP WRIGHT, JAMES YOCUM, ALEX ZAETS, LUIS ZAVALA, GEORGE K. ZINK, REBECCA ABAD, THOMAS ADLER, BIB IAN AFABLE, MICHAEL AKIN, SUREN ALAVERDYAN, DORAALDRETE, KARL AMRINE, ELMER ANDERSON, ERIC ANDERSON, PAMELA ANDERSON, SABRINA ANDERSON, DONALD ANDREWS, DAVID APPEL, OLGA ARANIVA, ANTONIO ARCINAS, ROBERT ARRINGTON, EWY AXELS SON, JOHN BAHURA, GLORIA BAILEY, IRMA BAKER-PARRA, BRUCE BARMAKIAN, RODRICK BARNETT, KEVIN BATMAN, LORI BATMAN, DAVID BEAUBIEN, MARILYN BEAUBIEN, AMANDA BENNETT, GEORGE BENNETT, ANNETTE BERRY, ROBERT BERRY, ALVIN BLAKE, TAW ANA BLAKE, CAROLE BOOTH, JOHN BOOTH, ARACELI BOWMAN, BILLY BOWMAN, PATRICK PAYGARBOYD, BARRY BOZARTH, ARNOLD BRIGMAN, DEBORAH BRIGMAN, VALERY BUBELA, BONNIE BUCKLEY, TOBY BUTTERWORTH, NELIDA CAMPOS, JERRY CANAD AY, MARIAN CANADY MEIXNER, GEORGE CASTRO, FRANCIS CELO, CARLOS CERVANTES, ROSE CHANG, JOHN CHARLSON, KATHERINE CHARLSON, DANIEL CHAVEZ, JOSEPH CHAVOEN, JOSEPH CINA, GRANT CLARK, SONIA CLARK, HUGH COLLINS, SEAN COMBS, ARTURO CONCHA, CHERIECOOK, DENISE COOK, RANDALL COOK, BENJAMIN CORONA, DIONICO CORTEZ, BERTHA CREVOLIN, RONNIE CREVOLIN, MATTHEW CROSBIE, CARYCRUZ, ROSEMARY CRUZ, HOUSTON CURTIS, ERIC CUTLER, CHARLES DANIELS, CHRISTINA DANIELS, RICARDO DAVALOS, CURTIS DAVIDSON, TROY DAVIS, SARGIS DAVODDANIEL, DON DECKER, TAMMY DECKER, PAZ DIAZ, OLIC DUNNING III, DAVID EB AD AT, HOTOSA EBRAHIMZADEH, KENNETH EDGECOMBE, NICOLE EDGECOMBE, MEHRDAD EMSHA, MARTIN ESCOBEDO, YOLANDA ESCOBEDO, ENRIQUETA ESPINOSA, FELIPA ESPINOSA, FRANCISCO ESPINOSA, JOSE ESPINOSA, DAVID ESTRADA, TY ETTERLEIN, FATEMEH FADAKAR, DAVID FAULHABER, MICHELLE FAVAZZO, ROGER FENSTERMACHER, LIZETTE-MILAN FIEDLER, FUMIKO FISHER, RICHARD FOMIN, LOURDES FONTZ, WAYNE FONTZ, ROGER FOSDICK, - 3 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 4 of 414 PagelD #: 770 SUSAN FRANCO, JAMES FRASER, JO ELLEN FRASER, DANN FRIEND, MATTHEW FRIEND, PHILLIP GALERA, BENJAMIN GAMEZ, JOSEFINA PEREZ GARCIA, ANTHONY GOLDEN, JOSEPH GOMEZ, ANA GONZALEZ, ESTER GONZALEZ, OSCAR GONZALEZ, ROBERT GRAHAM, RONNIE GREEN, SUSANNA GREEN, GRETA GREGORIO, STEVEN GUMIENNY, BRIAN GURNEE, AHMAD HAKIMJAVADI, RICHARD HALE, JACK HALLEY, TRACEY HAMPTON, CHERISE HANSSON, STEVEN HARDIE, CINDY HARRISON, JOAN HENDERSON-BROWN, LESLIE HENDRICKS, RUSSEL HENDRICKS, CENOBIO HERNANDEZ, LEONARD HERNANDEZ, MODJULJTA HERNANDEZ, ALFREDO HERRERA, LORENA HERRERA, MARIO HERRERA, BRETT HESKETT, RIZZA HESKETT, RAYMOND HILL, ARMANDO HINOJOSA, HEATH HODEL, SALVADOR HUIZAR, PATRICK HUNT, JOSEPH IGNACIO, REBECCA IGNACIO, CYNTHIA IRELAND, CLARENCE IRVING, EVELYN IRVING, MUHAMMAD ISLAM, GLEN JACKSON, HILLARY JACKSON, PAUL JACKSON, JESSE JOHNSON, NICHOLAS JONES, JEAN JOSEPH, MARIE JOSEPH, GUS KATSIKIDES, CASEY KAUER, JENNIFER KAUER, JOHNKEALY, KEVIN KEEHL, CARLEEN KELLER, DENNIS KEMP, GLORY KENNISON, LANCE KENNISON, BARBARA KIKUGAWA, CHRIS KIM, JAY KIM, LYNN KIMBERLY, LOUIS KLEIN, HARKRISHNAN KOCHAR, JASPAL KOCHAR, BRENT KOMOUROUS, DEANKRAEMER, JOSHUA KREITZER, KATHRYN T. KREITZER, PETEKREUZER, MAZLINA LAI, STEPHANIE LANDEN, JENNIFER LANGLO, ASHLEY LARSEN, CHRISTIAN LARSEN, BRUCE LA WSON, TRAVIS LEAGE, LISA LEFEBVRE, RAYMOND LEFEBVRE, JACK LEFLER, JOELLA LEFLER, JACQUELYNN LEONARDO, CARMEN LINARES, LUIS LINARES, ED LIZARD O, LINDA LIZARDO, CHERYL LOCEY, LAUREN LOCEY, DANILO LUQUIAS, YOLINA LUQUIAS, JOHNMACIAS, LOUIS MAGES, PATRICIA MAGES, STEFAN MAHALEY, HEATHER MAHONEY, DENIS E MANRIQUEZ, LAURIE MARINO, EDUARDO MARQUEZ, ELNORA MARSHALL, BRUNO MARTINEZ, FRANK MARTINEZ, MELANDO MARTINEZ, MIKE MARTINEZ, ELIZABETH MATSIK, CALVIN MATTHEWS, ELIZABETH MCCULLOUGH, SEAN MCDONALD, MARY MEDINA, DAVID MEDLIN, BRUCE MILLIGAN, RENE MINNAAR, RABIA MIR, MARIA MIRANDA, TOBY MOORE, LEONIDES MORALES, ERICA MORGERA, PETE MORGERA, BASHEER MURAD, CAAMIE MURAD, VALLIUR NADU, HIROSHI NAKAYAMA, YOLANDA NATIVIDAD, MARIA NAVARRO, OSCAR NAVARRO, ALAN NESS, SANDRA NESS, DIANA NEWSON, RALPH NEWSON, ANNA NGUYEN, MICHELLE NUNIES, JOHN OCAMPO, NOEL OLIVARES, ROMAN OLIVOS, MELISSA OWEN, MICHAEL OWEN, JOHN OXIDINE, JUAN PADILLA, MECIA PADILLA, JOSE PANTOJA, MARIA PANTOJA, ALAN PARSONS, CINDY PATELSKI, KAZIMIR - 4 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 5 of 414 PagelD #: 771 PATELSKI, MARIA PELCASTRE, MARIO A. PERALTA, RICARDO PEREZ, JAMES PETERSON, VIRGINIA PETERSON, JOHN PHILLINGANE, CAROL POWERS, DOUGLAS POWERS, ANNA MARIA PREZIO, REBECCA QUICK, STEVEN QUICK, WILLIAM RABELLO, NOOROLLAH RAHDAR, ELISEO RAMOS, ISRAEL RAPURI, DINYAHREIN, NORMAN JAY REST, EDITHA RESTAURO, DONALD REY, NANCY RILEY, BARBARA ROBINSON, STEPHEN ROBINSON, ARTHUR RODRIGUEZ, JOSE LUIS RODRIGUEZ, MARCIANO RODRIGUEZ, ETHAN ROSS, VIRGINIA ROTRAMEL, FLORENCE SABAGQUIT, JESSE SABAGQUIT, GUILLERMO SANCHEZ, DERRICK SANDERS, CARL SANKO, JOSEPH SANTOS, SIMON SARKISIAN, DAN SCHWARTZ, BRANNON SCIANNA, MARCIA SCIANNA, DEBBIE SCIORTINO, JOHN SCIORTINO, COURTNEY SCOTT, CRANFORD SCOTT, SHEILA SCOTT, BRIAN SEXSON, PETER SHELDON, SCOTT SHUBB, PAUL SIBORO, JULIET SICSIC, BAYAANI SIMPLICIANO, BALDEV SINGH, BALJIT SINGH, JOANNA SINGH, ALICE SMITH, CHARLEY SMITH, MARK SMITH, NIDA SMITH, WILLIE SMITH, MILTON SMITH II, JOANNE SNYDER-DAVIDSON, DIEP SOMMERS, RICHARD SORENSEN, HEMALATHA SOURI-P ARSONS, ROBBIN STITES, ALINA STROUP, GEORGE STROUP, SUZANNE SUGGS, SHYAM SUNDER, SALLY SYMONS, GILDA TAHMURESZADEH, ASHMELLEY THERVIL, KEVIN THOMPSON, BOBTIDD, BETTY TIMBERS, SONIKA TINKER-REIN, ANDREY TODOROV, ADNAN TORIAK, ALMA TOWNSEND, GREG TOWNSEND, MARY JANE TUMA, TIMOTHY TUMA, TONY TURTURICI, CINDY VICKERY, WILLIAM VICKERY, ELIAS VIEYRA, ENRIQUE VILLANUEVA, REBECCA VILLANUEVA, NADIA VILLARREAL, CHRISTOPHER VILLARUZ, LINDA H. VO, PATRICK VUONG, LAURA WALDHEIM, MICHAEL WALDHEIM, JILL WALKER, KEVIN WALKER, ZANE WALKER, GURMEET WARAICH, HARJINDER WARAICH, MELISSA WARNER, STEPHEN WAYNE, WALTER WEISS, EDNAWENNING, JAMIE WETZEL, JIM WETZEL, TODD WIDENER, VERONICA WIDENER, MELISSA WIDLUND, TIMOTHY WIDLUND, CRAIG WILLIAMS, ANN WILSON, RICHARD WILSON, EDWIN ALDANA, AUDRENE ANN ALENCASTRE- ROBERTS, LEPHAS BAILEY, GURDAYAL BATNA, KAMLESH BATNA, DARLENE BEEKS, JAMES BEEKS, ANDRES BENAVIDEZ, EDWARD BOSTOCK, SUZAN BRITT AN - BERGMAN, CARLA CALER, NORMAN CALER, STEVEN CAMPANELLI, JOSE CAMPOS, MARIA ANTONIA CANALES, GERARD CANNELLA, MELANIE CANNELLA, LARRY CAPOTS, ANDRES CARDENAS - BENAVIDEZ, BRIAN CARLSON, JON CARLSON, KIMBERLY CARLSON, LUCY CARLSON, DAWN CARMICHAEL, KIRK CARMICHAEL, JACQUELINE CARROLL, JOSEPHINA CASELLON, SHAWN CASSIDY, ANTONIO CHAVEZ, JOSE CHAVEZ, MARY CLOWNEY, WILLIAM CLOWNEY, HUGH COLLINS, BRENDA - 5 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 6 of 414 PagelD #: 772 COPPER, DEAN COPPER, MARIA CRUZ, CHRISTINE DAO, AVELINA DIZON, HONORIO DIZON, SANDRA DUARTE, JOSE DUARTE LEMUS, ANA DUENAS, STEVEN EHLERS, MICHELLE FA VAZZO, WILFREDO FELICIANO, SALLY FIGUEIREDO, FELICIA FLORES, CARLOS FLORES-CARRILLO, DIANE FORSMAN, CORRINE FRAYSINETTE, ANTONIO FUENTES, MARIA ELENA FUENTES, VICKI FURR, WAYNE FURR, OSCAR GARCIA, ROBERT GREGG, MAGDALENA GUIZAR, DARLENE N. HOLLO WAY, RALPH HOLLOW AY, HARLEY HUNTER, JEAN HUNTER, GERDA HYPPOLITE, JOSEPH IGNACIO, REBECCA IGNACIO, ROGER JAMES, ARMANDO JIMENEZ, JAVIER JIMENEZ, SANDY JIMENEZ, DIANE KEPLEY, RICHARD KEPLEY, GLADYS KRANTZ, RICHARD KRANTZ, DEBORAH LAMB, MANUEL LAND A VAZO, SHERRIE LANDOVASO, THEINLAMLE, KEN LEON, CONSUELO LOMBERA, HILARIO LUCERO, ADELFO MACASA, LEONARDA MACASA, JANET MARSHALL, JULIO MARTINS, ROBERTO MEDINA, BRUCE MILLIGAN, BAHMAN MIRSHAFIEE, FARAHNAZ MIRSHAFIEE, KIMBERLY MITCHELL, WILLIAM MITCHELL, MARIA MOULES, JOSENARIO, STEVEN NEWTON, KAREN NIERHAKE, CINDY OCHOA, DEANA OSEGUERA, JOSE OSEGUERA, MANUEL CASTRO PALMA, ROMINA PAREDES, KEN PARKER, DONPEDEN, SOCORRO PEREDA, IRVING PHAN, LUZ RAMIREZ, SEYED RAZAVI, GERALD ROBERTS, LISA RODRIGUEZ, JOSEPH R. RODRIGUEZ JR., OFELIA ROMERO, JOE SALAZAR, REGINALD SANTIAGO, MICHAEL SANTOS, YVONNE SANTOS, GEORGE SEELEY, TERRY SHAFFER, CHERYL SHAW, CHRISTINE SHIPMAN, JAMES SHIPMAN, ANABEL SILVA, MARTIN SILVA, MIKE SMITH, JONNY MARIE TORRES, JORGE TORRES, CHARLOTTE O. TUCKER, WILLIAM TUCKER, THEREISI VILLARUZE, HUY VO, DAVID WALLACE, VICTORIA WALLACE, KLAUDIA WILCZKOWIAK, JAMES WRAY, LEROY ANDERSON, ALEXANDER ARRORACI, RENEE BAYLIS, DENNIS BULMER, RICHARD CARROLL, DORIS COBURN, GEORGE COBURN, KC CRANDALL, KEITH DENSON, SALLY FIGUEIREDO, CHERYL FORD, EDGART GONZALEZ, STEVE KONG, JEFF LAVENDER, MARA LAVENDER, ROBERT LEWIN, JAMES LOCKER, AVELINO MARTINEZ, AIDA MEZA, JOSE MEZA, VIRGEN MONDRAGON, WILLIAM OAKS, DOMINADOR RAMOS, PETRONILLA RAMOS, ESME ROSS, ROBERT ROSS, CHRISTINE SHIPMAN, JAMES SHIPMAN, CHARLES TAM, RUBY TAM, RAYMOND TRAN, ROBERTO VARGAS, RUTH VARGAS, RONALD WILLIAMS, NASIR FAIZI, JULIE KESTENBAUM, PAUL KESTENBAUM, SPENCER GARNER, DANIEL FREEMAN, LARRY CONTIER, KAREN CONTIER, CLARISSE PICHE, MAURICIO BARRAGAN, RAFAEL RIVIRA, PATRICIA SMITHSON, LYNDEN SMITHSON, JOYCE GALVEZ, DEJAN JUROKOV, HEWLETT DAN QUILLEN, TROY DANELLA, LORRAINE DANELLA, ROGER STEWART, - 6 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 7 of 414 PagelD #: 773 NANCY MAE MARESH, JUDITH ANNE BLAIR, ALICE TOMASELLO, CONNIE PATTERSON, TERI SKRDLA, MIKE SKRDLA, JOHN KRUMSIEK, ANDREW P. BUCKLEY, BONNIE BUCKLEY, STEVE PASION, JANICE PASION, BELINDA KRUMSIEK Plaintiffs, -against- BANK OF AMERICA, N.A., BANK OF AMERICA CORPORATION, ERIC HOLDER, an individual, ANTHONY WEST, an individual, UNITED STATES OF AMERICA, as an involuntary plaintiff, THE STATE OF NEW YORK, as an involuntary plaintiff, JON CORZINE, an individual, VALERIE JARRETT, an individual, KAMALA HARRIS, an individual, MYA HARRIS-WEST, an individual, ANNITA DUN, an individual, ROBERT BAUER, an individual, JEREMY BEN-AMI, an individual, J STREET, INC., an entity form unknown, HOWARD DICKSTEIN, an individual, JENNINE ENGLISH, an individual, THOMAS V. GIRARDI, an individual, WALTER LACK, an individual, ERIC GEORGE, an individual, SANDOR SAMUELS, an individual, ALAN ROTHENBERG, an individual, THOMAS LAYTON, an individual, JOHN HOONEN, an individual, DAVID BROCK, an individual, PETER KRAUSE, an individual, MARY ROBERTS, an individual, MEDIA MATTERS, a corporation form unknown, DANIELLE LEE, an individual, JOSEPH DUNN, an individual, JERRY FALK, an individual, DOUGLAS WINTHROP, an individual, KENNETH LEWIS, an individual, TODD TORR, an individual, JEFFREY HUVELLE, an individual, JOSEPH CRUDO, SR., an individual, JOSEPH CRUDO, JR, an individual, MICHAEL BROSNAN, an individual, WILLIAM WARDLAW, an individual, ALAN I. ROTHENBERG, an individual, DAVID J. PASTERNAK, an individual, HOWARD MILLER, an individual, SCOTT DREXEL, an individual, 1 CENTURY BANK aka FIRST CENTURY BANK, an entity form unknown, FIRST CENTURY BANKSHARES, INC., a Delaware corporation, COUNTRYWIDE FINANCIAL CORPORATION, dba BAC HOME LOANS SERVICING,COUNTRYWIDE HOME LOANS, INC., JP MORGAN CHASE BANK, N.A., in its own capacity and as an acquirer of certain assets and liabilities of Washington Mutual Bank; CHASE HOME FINANCE, LLC, WELLS FARGO & COMPANY, WELLS FARGO BANK, N.A., WACHOVIA BANK, CITIGROUP, INC., CITIBANK, N.A., U.S. BANCORP, U.S. BANK, N.A., U.S. BANK TRUST COMPANY, NATIONAL ASSOCIATION, U.S. BANK TRUST NATIONAL ASSOCIATION, ALLY BANK, N.A., in its own capacity and as an acquirer of certain assets and liabilities OF GMAC, GENERAL MOTORS ACCEPTANCE CORPORATION, ONEWEST BANK, F.S.B., HSBC HOLDINGS, INC., AURORA BANK, F.S.B., OCWEN - 7 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 8 of 414 PagelD #: 774 FINANCIAL CORPORATION, DEUTSCHE BANK AG, DEUTSCHE BANK NATIONAL TRUST COMPANY, EMC CORPORATION, EMC MORTGAGE CORPORATION, PNC BANK, N.A., DSfG GROUP, COUNTRYWIDE ALTERNATIVE ASSET MANAGEMENT, COUNTRYWIDE ALTERNATIVE INVESTMENTS, COUNTRYWIDE CAPITAL I, COUNTRYWIDE CAPITAL II, COUNTRYWIDE CAPITAL III, COUNTRYWIDE CAPITAL IV, COUNTRYWIDE CAPITAL V, COUNTRYWIDE CAPITAL VI, COUNTRYWIDE CAPITAL VII, COUNTRYWIDE CAPITAL VIII, COUNTRYWIDE CAPITAL IX, COUNTRYWIDE CAPITAL MARKETS ASIA (HK) LIMITED, COUNTRYWIDE CAPITAL MARKETS, COUNTRYWIDE COMMERCIAL JPI LLC, COUNTRYWIDE COMMERCIAL MORTGAGE CAPITAL, COUNTRYWIDE COMMERCIAL REAL ESTATE FINANCE, COUNTRYWIDE HILLCREST I, COUNTRYWIDE INTERNATIONAL GP HOLDINGS, COUNTRYWIDE MANAGEMENT CORPORATION, COUNTRYWIDE MORTGAGE VENTURES, LLC, COUNTRYWIDE INTERNATIONAL TECHNOLOGY HOLDINGS LIMITED, COUNTRYWIDE WAREHOUSE LENDING, CWABS II, INC., CWALT, INC., CYRUS ACCESS, LTD., DIVERSIFIED ALPHA FUND (MASTER), LTD., HALCYON ACCESS, LTD., INDOPARK HOLDINGS, LTD., INVESTMENTS 2234 PHILIPPINES FUND I (SPV-AMC), INC., ML BANDERIA CAYMAN BRL INC.,ML WHITBY LUXEMBOURG S.A.R.L., ZEUS RECOVERY FUND, S.A., LP. MORGAN MANSART INVESTMENTS, SAPOTORO COOPERATIEF U.A., ONE EQUITY PARTNERS II, L.P., ONE EQUITY PARTNERS III, L.P., ONE EQUITY PARTNERS IV, L.P., ONE EQUITY PARTNERS LLC, BEAR STEARNS INTERNATIONAL FUNDING I S.A R.L., J.P. MORGAN DUBLIN FINANCIAL HOLDINGS LIMITED, J.P.MORGAN FINANCE JAPAN YK, J.P. MORGAN SERVICES INDIA PRIVATE LIMITED, HENRY BATH BV, GAVEA INVESTIMENTOS LTDA., J. P. MORGAN RESEARCH TOTAL RETURN MASTER FUND LTD, JPMORGAN DISTRESSED DEBT MASTER FUND LTD. , JPMORGAN GREATER CHINA PROPERTY FUND CAYMAN SLP LP, JPMORGAN ASSET MANAGEMENT HOLDINGS (LUXEMBOURG) S.A R.L., JPMORGAN ASSET MANAGEMENT LUXEMBOURG S.A., J.P. MORGAN CHASE CUSTODY SERVICES, INC., ATACAMA MULTIMERCADO - FUNDO DE INVESTIMENTO, J.P. MORGAN S.A. DISTRIBUIDORA DE TITULOS E VALORES MOBILIARIOS, J.P. MORGAN BANK LUXEMBOURG S.A., BANCO J.P. MORGAN S A., INSTITUCION DE BANCA MULTIPLE, J.P. MORGAN GRUPO FINANCIERO, J.P. MORGAN INTERNATIONAL HOLDINGS LIMITED, JPMORGAN CHASE BANK (CHINA) COMPANY LIMITED CHINA, JPMORGAN PCA - 8 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 9 of 414 PagelD #: 775 HOLDINGS (MAURITIUS) I LIMITED, DANUBE HOLDINGS I C.V., DANUBE HOLDINGS III C.V., EUROPEAN CREDIT FUND SICAV II, EVERGREEN ECM HOLDINGS B.V., GOLDEN FUNDING COMPANY, ISLAND FINANCE HOLDING COMPANY, LLC, JORDAN INVESTMENTS LP UK, NORWEST VENTURE PARTNERS FII SINGAPORE PRIVATE LIMITED, NORWEST VENTURE PARTNERS FVCI SINGAPORE PRIVATE LIMITED, NORWEST VENTURE PARTNERS SINGAPORE PRIVATE LIMITED, NORWEST VENTURE PARTNERS VI, LP, NORWEST VENTURE PARTNERS VI-A, LP, NORWEST VENTURE PARTNERS VII, LP, NORWEST VENTURE PARTNERS VII-A FII MAURITIUS, NORWEST VENTURE PARTNERS VII-A FVCI MAURITIUS, NORWEST VENTURE PARTNERS VII-A MAURITIUS, OVERLAND RELATIVE VALUE FUND LTD., OVERLAND RELATIVE VALUE MASTER FUND LP, PARTNERSHIP INVESTMENTS S A.R.L., CITIBANK (CHINA) CO., LTD., CITIBANK DEL PERU S.A., CITIBANK MAGHREB, BANCO CITIBANK DE GUATEMALA, S.A., BANCO CITIBANK S.A., CHELSEA PARTICIPACOES SOCIETARIAS E INVESTIMENTOS LTDA., CITIBANK - DISTRIBUIDORA DE TITULOS E VALORES MOBILIARIOS S.A., DEFENDANTS NO. 151 THROUGH NO. 1808: "NEW YORK LOAN POOLS" (ATTACHED AS EXHIBIT "A" HERETO); CITIFINANCIAL PROMOTORA DE NEGOCIOS & COBRANCA LTDA., CITIBANK CORRETORA DE SEGUROS LTDA., BANCO CITICARD S.A., BANK HANDLOWY W WARSZAWIE S.A., CITI OVERSEAS INVESTMENTS BAHAMAS INC., CITIBANK CARTOES PARTICIPACOES LTDA., CITIGROUP GLOBAL MARKETS, CORPORATION & CO. BESCHRANKT HAFTENDE KG, CITIGROUP GLOBAL MARKETS DEUTSCHLAND AG, CITIBANK MEDIADOR, OPERADOR DE BANCA - SEGUROS VINCULADO, SOCIEDAD ANONIMA, CITIBANK HOLDINGS IRELAND LIMITED, CITICORP CAPITAL PHILIPPINES, INC., CITICORP FINANCE (INDIA) LIMITED, CITIGROUP ASIA PACIFIC HOLDING CORPORATION, CITIGROUP HOLDING (SINGAPORE) PRIVATE LIMITED, CITIBANK (HONG KONG) LIMITED, CITIBANK BERHAD, CITIBANK MALAYSIA (L) LIMITED, CITIGROUP NETHERLANDS HOLDINGS B.V., LATIN AMERICAN INVESTMENT BANK BAHAMAS LIMITED, ZAO CITIBANK, CITIGROUP GLOBAL MARKETS LUXEMBOURG, CITIGROUP GLOBAL MARKETS, HOLDINGS LIMITED, CITIGROUP GLOBAL MARKETS, HOLDINGS PTE. LTD., CITIGROUP GLOBAL MARKETS, SINGAPORE PTE. LTD., CITIGROUP GLOBAL MARKETS INDIA PRIVATE LIMITED, CITIGROUP GLOBAL MARKETS COMMERCIAL CORP., COHM OVERSEAS MEXICO HOLDING, S. DE R.L. DE C.V., ELAVON DO BRASIL SOLUCOES DE PAGAMENTO S.A., ELAVON EUROPEAN HOLDINGS B.V., ELAVON EUROPEAN HOLDINGS C.V., ELAVON FINANCIAL SERVICES LIMITED, USB NETHERLANDS B.V., USB REALTY CORP., USB TRADE SERVICES LIMITED, - 9 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 10 of 414 PagelD #: 776 ELAVON MERCHANT SERVICES MEXICO, S. DE R.L. DE C.V., ELAVON MEXICO HOLDING COMPANY, S.A. DE C.V., ELAVON OPERATIONS COMPANY, S. DE R.I. DE C.V., ELAVON PUERTO RICO, INC., ELAVON SERVICES COMPANY, S. DE R.I. DE C.V., GMAC HOLDINGS GMBH, GMAC GERMANY GMBH & CO. KG, GMAC BANK GMBH, GMAC HOLDINGS U.K. LIMITED, GMAC UK PLC, GMAC INTERNATIONAL HOLDINGS B.V., ALLY CREDIT CANADA LIMITED, GMAC INTERNATIONAL FINANCE B.V., ABA SEGUROS, S.A. DE C.V., ALLY INTERNATIONAL INSURANCE COMPANY, LTD., GMAC CYPRESS HOLDINGS LIMITED, BANCO GMAC S.A., RESMOR CAPITAL CORPORATION, RESMOR TRUST COMPANY, U.S. TRUST CORPORATION, BANK BOSTON, BANK OF AMERICA (Asia), CHINA CONSTRUCTION BANK (Asia) CORPORATION LIMITED, BANK OF AMERICA (Macau), CHINA CONSTRUCTION BANK (Macau), CHINA CONSTRUCTION BANK (Macau), BANK OF AMERICA CANADA, BANC OF AMERICA SECURITIES LLC, MBNA AMERICA BANK, NATIONAL ASSOCIATION, FIA CARD SERVICES, NATIONAL ASSOCIATION, FIA CARD SERVICES, NATIONAL ASSOCIATION, RED OAK MERGER CORPORATION, MERRILL LYNCH, MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED, BANCAMERICA ROBERTSON STEPHENS, KLEIN BANK, and DOES 2 through 1000, inclusive, said names being fictitious, it being the intention of the Plaintiffs to designate any and all entities involved in the acts of malfeasance alleged herein, the true names of the fictitious Defendants are otherwise unknown at the present time and will be supplemented by amendment when ascertained, Defendants. - 10 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 11 of 414 PagelD #: 777 PRESS RELEASE NEW YORK, NY— (10/25/12) — Spire Law Group, LLP's national home owners' lawsuit, pending in the venue where the "Banksters" control their $43 trillion racketeering scheme (New York) - known as the largest money laundering and racketeering lawsuit in United States History and identifying $43 trillion ($43,000,000,000,000.00) of laundered money by the "Banksters" and their U.S. racketeering partners and joint venturers - now pinpoints the identities of the key racketeering partners of the "Banksters" located in the highest offices of government and acting for their own self- interests. In connection with the federal lawsuit now impending in the United States District Court in Brooklyn, New York - involving, among other things, a request that the District Court enjoin all mortgage foreclosures by the Banksters nationwide, unless and until the entire $43 trillion is repaid to a court-appointed receiver - Plaintiffs now establish the location of the $43 trillion ($43,000,000,000,000.00) of laundered money in a racketeering enterprise participated in by the following individuals (without limitation): Attorney General Holder acting in his individual capacity, Assistant Attorney General Tony West, the brother in law of Defendant California Attorney General Kamala Harris (both acting in their individual capacities), Jon Corzine (former New Jersey Governor), Robert Rubin (former Treasury Secretary and Bankster), Timothy Geitner, Treasury Secretary (acting in his individual capacity), Vikram Pandit (recently resigned and disgraced Chairman of the Board of Citigroup), Valerie Jarrett (a Senior White House Advisor), Anita Dunn (a former "communications director" for the Obama Administration), Robert Bauer (husband of Anita Dunn and Chief Legal Counsel for the Obama Re-election Campaign), as well as the "Banksters" themselves, and their affiliates and conduits. The lawsuit alleges serial violations of the United States Patriot Act, the Policy of Embargo Against Iran and Countries Hostile to the Foreign Policy of the United States, and the Racketeer Influenced and Corrupt Organizations Act (commonly known as the RICO statute) and other State and Federal laws. In the District Court lawsuit, Spire Law Group, LLP — on behalf of home owner across the Country and New York taxpayers, as well as under other taxpayer recompense laws — has expanded its mass tort action into federal court in Brooklyn, New York, seeking to halt all foreclosures nationwide pending the return of the $43 trillion ($43,000,000,000.00) by the "Banksters" and their co- conspirators, seeking an audit of the Fed and audits of all the "bailout programs" by an independent receiver such as Neil Barofsky, former Inspector General of the TARP program who has stated that - 11 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 12 of 414 PagelD #: 778 none of the TARP money and other "bailout money" advanced from the Treasury has ever been repaid despite protestations to the contrary by the Defendants as well as similar protestations by President Obama and the Obama Administration both publicly on national television and more privately to the United States Congress. Because the Obama Administration has failed to pursue any of the "Banksters" criminally, and indeed is actively borrowing monies for Mr. Obama's campaign from these same "Banksters" to finance its political aspirations, the national group of plaintiff home owners has been forced to now expand its lawsuit to include racketeering, money laundering and intentional violations of the Iranian Nations Sanctions and Embargo Act by the national banks included among the "Bankster" Defendants. The complaint - which has now been fully served on thousands of the "Banksters and their Co- Conspirators" - makes it irrefutable that the epicenter of this laundering and racketeering enterprise has been and continues to be Wall Street and continues to involve the very "Banksters" located there who have repeatedly asked in the past to be "bailed out" and to be "bailed out" in the future. The Havens for the money laundering schemes - and certain of the names and places of these entities - are located in such venues as Switzerland, the Isle of Man, Luxembourg, Malaysia, Cypress and entities controlled by governments adverse to the interests of the United States Sanctions and Embargo Act against Iran, and are also identified in both the United Nations and the U.S. Senate's recent reports on international money laundering. Many of these entities have already been personally served with summons and process of the complaint during the last six months. It is now beyond dispute that, while the Obama Administration was publicly encouraging loan modifications for home owners by "Banksters", it was privately ratifying the formation of these shell companies in violation of the United States Patriot Act, and State and Federal law. The case further alleges that through these obscure foreign companies, Bank of America, J.P. Morgan, Wells Fargo Bank, Citibank, Citigroup, One West Bank, and numerous other federally chartered banks stole trillions of dollars of home owners' and taxpayers' money during the last decade and then laundered it through offshore companies. This District Court Complaint - maintained by Spire Law Group, LLP — is the only lawsuit in the world listing as Defendants the Banksters, let alone serving all of such Banksters with legal process and therefore forcing them to finally answer the charges in court. Neither the Securities and Exchange Commission, nor the Federal Deposit Insurance Corporation, nor the Office of the - 12 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 13 of 414 PagelD #: 779 Attorney General, nor any State Attorney General has sued the Banksters and thereby legally chased them worldwide to recover-back the $43 trillion ($43,000,000,000,000.00) and other lawful damages, injunctive relief and other legal remedies. James N. Fiedler, Managing Partner of Spire Law Group, LLP, stated: "Why did it take a private law firm to reveal the biggest secret regarding the Obama Administration, especially after the prior Bush Administration appointed a competent Democrat - Neil Barofsky - to head up the TARP program? What has the Administration done to recover back these trillions of dollars, since April, 2012 when this complaint was first filed? Why hasn't the Administration acted to investigate or fire Holder, engaged in conflicts of interest with outside lawyers while he purports at the same time to act for the public good as U.S. Attorney General? What exactly does Timothy Geitner do for a living, other than preside over the laundering and racketeering of trillions of dollars? Why has no Bankster been sued or indicted by any of the foregoing public officials, while they concurrently steal trillions of dollars and transfer them to Luxembourg? Former FDIC Chairman Shiela Bair said that the "bailout" benefitted 'solely the Banksters and all regular American citizens were left to fend for themselves.'" Spire Law Group, LLP's charter is to not allow such corruption to go unanswered." Comments were requested from the Attorney Generals' offices in NY, CA, NV, NH , OH, MA and the White House, but no comment was provided. About Spire Law Group Spire Law Group, LLP is a national law firm whose motto is "the public should be protected — at all costs — from corruption in whatever form it presents itself." The Firm is comprised of lawyers nationally with more than 250-years of experience in a span of matters ranging from representing large corporations and wealthy individuals, to also representing the masses. The Firm is at the front lines litigating against government officials, banks, defunct loan pools, and now the very offshore entities where the corruption was enabled and perpetrated. - 13 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 14 of 414 PagelD #: 780 TABLE OF CONTENTS Section Page I PRELIMINARY STATEMENT 17 II INTRODUCTION 17 III JURISDICTION AND VENUE 21 IV THE DEFENDANTS' THEFT OF $43 TRILLION FROM PLAINTIFFS, THEIR PRIVIES, AND OTHERS SIMILARY SITUATED THERETO 24 A. -Defendant Members of the Bankster Enterprise 24 B. -Illegal Schemes of the Bankster Enterprise 27 C. -Twenty Trillion Dollars of TARP and Other U.S. Monies Laundered 30 D. -The Nixonian "Enemies List" of the Obama Administration 33 E. -The New York Genesis of the Bankster Enterprise 35 i. The Initial Money 35 ii. Continual Influx of RICO Enterprise Money 35 iii. Other Location 35 F. -The Misappropriation of Laundering Money For Personal Bankster Uses 36 i. In excess of $590 Million Skimmed by the Tony West/Kamala Harris Syndicate 36 ii. In excess of $500 Million Skimmed by the Holder and George Syndicate 36 iii. In excess of $750 Million Skimmed to Sandor Samuels & Affiliates 37 iv. In excess of $780 Million Skimmed by Jeremy Ben- Ami, J Street & Affiliates, and Howard Dickstein ("The Dickstein Group") 37 v. In excess of $120 Million Skimmed by Robert Rubin Syndicate 37 - 14 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 15 of 414 PagelD #: 781 vi. In excess of $5 10 Million Skimmed by Jon Corzine Syndicate 38 vii. In excess of $100 Million Skimmed by Girardi-George- Rothenberg Syndicates 38 viii. In excess of $420 Billion Skimmed by the Geitner Syndicate 39 V PARTIES 39 A. -Plaintiffs 39 B. -Defendants 164 VI ADDITIONAL FACTS OF THE RICO, MONEY LAUNDERING AND PONZI SCHEMES 359 VII FIRST CLAIM FOR RELIEF - CONVERSION 375 VIII SECOND CLAIM FOR RELIEF - CONSPIRACY TO COMMIT CONVERSION 378 IX THIRD CLAIM FOR RELIEF - INTENTIONAL MISREPRESENTATION 379 X FOURTH CLAIM FOR RELIEF - INTENTIONAL MISREPRESENTATION 382 XI FIFTH CLAIM FOR RELIEF - FRAUDULENT CONCEALMENT 384 XH SIXTH CLAIM FOR RELIEF - FRAUDULENT CONCEALMENT 389 XIII SEVENTH CLAIM FOR RELIEF - PROMISSORY ESTOPPEL. 392 XIV EIGHT CLAIM FOR RELIEF - NEGLIGENT MISREPRESENTATION 393 XV NINTH CLAIM FOR RELIEF - BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING 394 XVI TENTH CLAIM FOR RELIEF - UNJUST ENRICHMENT 396 - 15 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 16 of 414 PagelD #: 782 XVII ELEVENTH CLAIM FOR RELIEF - VIOLATIONS OF N.Y. GEN. BUS. LAW §349 397 XVIII TWELFTH CLAIM FOR RELIEF - CIVIL RACKETEERING - 18 U.S.C. §1962 [C] 400 XIX THIRTEENTH CLAIM FOR RELIEF - CIVIL RACKETEERING - 18 U.S.C. Sec. 1962(d) 404 XX FOURTEENTH CLAIM FOR RELIEF - CIVIL RACKETEERING - 18 U.S.C. 1962(c), 1503 406 XXI FIFTEENTH CLAIM FOR RELIEF - THAT DODD-FRANK LEGISLATION AND ITS APPLICATION IS VIOLATIVE OF THE FOURTEENTH AMENDMENT TO THE UNITED STATES CONSTITUTION AS APPLYING LAWS UNEQUALLY AND EXCLUDING FROM ITS AMBIT BANKS "TOO BIG TO FAIL" AS SUCH BANKS ARE PROTECTED BY THE DODD-FRANK LEGISLATION 411 XXII DEMAND FOR RELIEF 412 - 16 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 17 of 414 PagelD #: 783 The above-named Plaintiffs, by their attorneys, demand a jury trial and complain and allege as follows: I. PRELIMINARY STATEMENT 1. This lawsuit arises from, among other things: (1) the deception in inducing Plaintiffs to enter into loans and mortgages 1 from approximately 2003 through 2007 and which were acquired or are serviced by Defendants; (ii) the fraudulent and illegal use of MERS and other "camouflage entities" in connection with those loans and mortgages; (iii) Defendants' breach of Plaintiffs' statutorily protected rights; (iv) Defendants' breach and willful violation of numerous consumer and homeowner protection statutes, and willful violations of unfair business practices statutes, by, among other things, processing money from unknown sources, in contravention of the Patriot Act and the Racketeer Influenced and Corrupt Organizations Act; (v) accepting money, transferring alleged assets and foreclosing upon alleged assets in instances where the alleged assets do not exist, and in which these Defendants have no right, title, or interest upon which they can act; and (vi) Defendants' continuing conversion and other tortious conduct intended to deprive Plaintiffs of their money, property and legal rights and remedies for the foregoing acts, as described more fully below. (Hereinafter "Defendants' Scheme.") II. INTRODUCTION 2. The Defendants scheme was and continues to be a gigantic international money laundering, "ponzi" and racketeering enterprise in which Defendants - and each of them as set forth herein - deceived, defrauded, stole, laundered, transferred, hypothecated (collectively "ponzi" enterprise) and then increased the level of theft by stealing from the United States of America and injecting into the ponzi enterprise a grand total (including monies stolen from all 1 The words "mortgage" and "deed of trust" are used interchangeably throughout this Complaint. - 17 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 18 of 414 PagelD #: 784 plaintiffs) of $43-Trillion ($43,000,000,000,000.00) through the foregoing acts, through the acts set forth herein, and through supplemental acts continuing and ongoing as recently as the day prior to filing this complaint as follows (a) the deception in inducing Plaintiffs to enter into loans and mortgages and loan modification agreements and compromise agreements and other undertakings of any and all kinds and nature, from approximately 2003 through and including the date of this First Amended Complaint, and (b) the fabrication of documentation, charges, lawsuits, investigations and other modalities against the founders of Plaintiffs' counsel in this matter, lawyers throughout the United States, and any persons who were opposed to the theft of the entirety of at least 10X the United States of America's entire money supply ($43 trillion), all pertaining to the ponzi and racketeering schemes and money laundering intentions by the defendants as follows: 3. To direct and then divert the attention of involuntary plaintiff the United States of America, and all plaintiffs in this case, against the stoppage of real estate foreclosures in America and other impending foreclosures nationwide, include through utilization of false records and documents, and to concomitantly divert their attention away from the facts that (a) Defendants - and each of them - had come into possession of, laundered, stolen, transferred, fraudulently conveyed, subsequently transferred, hypothecated, and secreted (collectively "stolen" or "converted") (i) for their own personal use as set forth below and (ii) by transferring or subsequently converting the proceeds of the foregoing and other personalty into entities and persons located in jurisdictions that lack sufficient treaties with the United States of America in the total sum of more than $43 Trillion ($43,000,000,000,000.00), and (b) Defendants - and each of them - had as well stolen, converted and wrongfully utilized all personal financial information of each person in the United States who either has a social security number or a - 18 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 19 of 414 PagelD #: 785 driver's license (so-called persons on the "grid"), all representing (a) some 10 (ten) times the entire money supply of the United States of America, (b) substantially all the paper money the United States of America was able to print in a non-counterfeit-setting as of the dates the money was unlawfully printed and in the total sum of at least $20 Trillion out of the entire $43 Trillion stolen. While the defendants - and each of them - were able to hide the amounts of money and manner of the conspiratorial taking of money for individual profit and gain over the past decade due to various corrupt practices of officials acting far outside the course and scope of their employment, the public discourse is now replete with proof of the foregoing ponzi and racketeering schemes and concomitant money laundering enterprise by all Defendants (and in each case for personal gain) using entities that are Defendants herein and that also were or are fronts for drug cartels, terrorist groups or other unsourced money transferors and transferees violative of the United States Patriot Act, the Racketeer Influenced and Corrupt Organizations Act and other State and Federal laws. As of the date of this First Amended Complaint, Defendants continue to fraudulently transfer portions of the $43 trillion to other entities that they control, including the entities set forth on Exhibit "A" hereto. An asset freeze order pending appointment of an independent receiver, is required in order to safeguard and return the assets to the United States of America, Plaintiffs and other rightful owners thereto. 4. In other words, after the deafening sadness of the 9/1 1 assaults against the Country, the Defendants - each entering the conspiracy because of the confusion associated with the United States' focus on Homeland Security to protect the safety of its citizens - and for personal gain at various times throughout the past decade as set forth in great detail below and as the receiver for the United States of America and State of New York shall forensically audit for the benefit of Plaintiffs and all persons "on the grid" meant to receive the protection of the State - 19 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 20 of 414 PagelD #: 786 (US and New York) - the Defendants have actually and in fact engaged in the raping, pillaging and plundering of $43 Trillion ($43,000,000,000,000.00) as well as other personalty including clothing, automobiles, valuable jewelry, gold, silver, precious metals and all forms of valuable personal property known to man, so that the wealth of Plaintiffs and all citizens of the United States of America, and the wealth of the United States of America itself, were stolen as set forth above and herein to the few groups of Americans who calculated and hatched the foregoing plan in directly copying the modus operandi associated with the historical manner in which the Vikings raided, traded, explored and ultimately settled in wide areas of Europe, Asia and the North Atlantic islands from the late 8th to the mid- 11th Century. Included among the lawless activities of the Defendants has been the breaking and entering into homes of American citizens and stripping such homes of jewelry, fixtures, appliances and anything of value, without court order or approval, and with full knowledge that no court or legislative system could stop pillaging and plundering done with such speed, such detailed intention and such Viking-like efficiency. This lawsuit is necessary to avoid the looming financial crisis that shall occur as a result of the foregoing theft of $43 trillion-plus. Indeed, former TARP Inspector General Neil Banofsky has warned that another massive bailout will again be required if the money center banks and/or their principals are deemed "too big to jail." 5. To be specific and to assure no ambiguity, such pillage and plundering -which has transferred wealth of the United States by the sum of more than $43 Trillion to the hands of the Defendants, and each of them — neither George H. W. Bush nor George W. Bush (nor their subordinates) were a part of this plan, because it was hatched and implemented without their knowledge and it is undisputed that the proceeds of the plan were used to pay for the election of Barack Obama and a Democratic Congress in 2008, as well as various other state and local - 20 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 21 of 414 PagelD #: 787 officials who have then taken money personally as a part of the "Viking-like campaign" to steal all assets available to be stolen in the United States. The United States' judicial and legislative systems have been unable to stop the world's onslaught on the United States of America, and the executive branch of the government has made no such attempt either through nonfeasance, misfeasance or malfeasance. The United States of America and its citizens - plaintiffs herein and other victims similarly situated - require the issuance of broad injunctive relief to prevent any further theft and looting absent judicial review by one experienced federal judge acting with full jurisdictional authority as well as with knowledge gained from (and audited by) an independent and experienced court-appointed receiver. Such relief - which is a critical component of this lawsuit as well as the recovery of the stolen $43 Trillion - is vital to the future survival of the United States of America, and the financial security of Plaintiffs, their Privies and those similarly situated, and to prevent a further bailout of the Banksters. HI. JURISDICTION AND VENUE: 6. This Court has jurisdiction over the claims against each of the Defendants by way of 18U.S.C. § 1964. 7. Venue is proper in this judicial district under 18 U.S.C. § 1965, 28 U.S.C. § 1391, and 28 U.S.C. §§ 1408 and 1409(a). The injury to the business and property of the United States of America, the State of New York and Plaintiffs occurred in New York. The "loan pool" defendants and the specific Groups identified below (i) organized and directed the Illegal Scheme from, among other places, New York and from the specific New York addresses set forth below; (ii) fed the Ponzi and RICO schemes via the money laundering devices and the theft from the Fed of Trillions of Dollars (more than $43 trillion) through bank accounts ultimately located in New York; (iii) carefully guarded all evidence of the conspiracy - 21 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 22 of 414 PagelD #: 788 set forth herein at addresses set forth herein - and that will be further adduced during discovery - in New York, New York and nowhere else most of them being situated at J.P. Morgan Chase in New York and wired there through HSBC (the wire transfer enabler) as reported in the anti- terrorism report issued by the United States Senate in July, 2012 and attached hereto as Exhibit B; (iv) drew secret kickbacks (called "skimming") from one of thousands of bank accounts held by the numerous money-laundering, RICO defendants set forth herein for the personal benefit of those persons and their families in power who were able to manipulate the system and conduct such thefts of money. Venue is also proper in this judicial district under 18 U.S.C. § 1965(b) because, to the extent that any Defendant may reside outside of this district, the entire RICO and money laundering conspiracy depended upon Wall Street in order for it to be implemented and maintained, all master bank accounts tracking the proceeds of the $43 trillion ($43,000,000,000,000.00) stolen by the Defendants are located in New York city, all remaining paper evidence of the conspiracy and theft and looting of money remains in New York city, and the ends of justice require such Defendants to be brought before this Court. 8. Furthermore, this Court has jurisdiction over each of the non-domiciliary Defendants because each of them transacts business within the State of New York within the meaning of the foregoing statutes and State and Federal law, each of them committed tortious acts inside the State of New York or outside the State of New York causing injury within the State of New York within the meaning of State and Federal law; and/or the Defendants deposited the fruits of the fraud, the evidence of the Defendants' Scheme and their ponzi and RICO enterprises, and/or the ill-gotten gains therefrom, into banks, other like-institutions and/or into hiding places including bank vaults and other secret undercrofts within locations situated in the State of New York. - 22 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 23 of 414 PagelD #: 789 9. All transactions sued upon herein were transactions occurring exclusively in interstate and then international commerce. All subsequent transfers disclosed herein (whether or not fraudulent) emanated only from the State of New York or banks and/or financial institutions (e.g., "loan pools") which have New York as their principal place of business. 10. Venue is proper in this Court pursuant to State and Federal law, as all Defendants are either domiciled in New York city, or they regularly conduct business there and avail themselves of the benefits and protections of New York law there. Furthermore, venue is proper because all defendants agreed and co-conspired to the fraudulent transfers and subsequent transfers arising out of the tortious activity committed in the State of New York described herein. 11. Furthermore, venue is proper because involuntary plaintiff the United States of America - acting through Plaintiffs' standing as taxpayers to move for the appointment of a receiver to forensically audit and recover-back a sum that will eliminate the Country's deficit of $16 Trillion and any Medicare shortfalls merely by utilizing national and international law to recover back the $43 Trillion stolen - will be unable to reach the heart of the evidence and money without conducting daily and intensive judicial and extra-judicial discovery against Defendants, all of which assured that the fruits and evidence of their Scheme and ponzi/RICO enterprise are located physically near the supervisors thereof all of which are residents of the State of New York as set forth in detail hereof. 12. There should be no mistake: Plaintiffs allege and have direct evidence that this is a Wall Street-controlled Scheme and ponzi/RICO-enterprise, plain, simple, and . . . period. This episode of unparalleled greed and concomitant theft, could not have survived and flourished, without (a) the thousands of so-called "loan pools" which are defendants herein and operated to launder and hide the monetary, shady dealings of Defendants, and (b) the "wink and nod" from - 23 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 24 of 414 PagelD #: 790 regulators including the Obama Administration not to recover the monies from the Banksters or to prosecute them civilly or criminally, and (c) to continue to tell "the big lie" that all such stolen monies were repaid to the Treasury, as hundreds of millions of Americans saw on national television when the President himself said "the bailout monies have been repaid with interest." 13. Because the scheme of the Defendants has been unraveled and Defendants have been caught red handed, this Court is empowered to now take action that will eliminate all woes for both Plaintiffs (on a micro-economic basis) and for involuntary plaintiff the United States of America (on a macro-economic basis). Such relief will require that the injunctive relief also include a prohibition against any further "printing" of money by federal officials absent the Congressional approval and oversight normally attendant to such multi-trillion-dollar expenditures. Plaintiffs and the United States of America merely seek compliance with State and Federal law, and through an appropriate order of this Honorable Court the Defendants - who now hold $43 Trillion of Plaintiffs' and the United States' money - (a) can pay into the Court an amount necessary to assure propriety and efficacy in the appointment of a receiver and management of the recovery for the benefit of the United States of America and all citizens and (b) are ordered, barred and enjoined under the provisions of federal law set forth herein from reaping any further benefits of the "national bank settlement" which was signed through Defendants' fraud in not disclosing any of the foregoing facts to the Plaintiffs or to any American taxpayer. IV. THE DEFENDANTS' THEFT OF $43 TRILLION FROM PLAINTIFFS, THEIR PRIVIES, AND OTHERS SIMILARY SITUATED THERETO A. Defendant Members of the Bankster Enterprise 14. The members of the Bankster Enterprise are individuals and entities - foreign and domestic - who carefully planned this "reverse-run-on-the-bank" (i.e., this theft and looting of - 24 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 25 of 414 PagelD #: 791 the assets of Plaintiffs and the assets of millions of Americans beginning after 9/1 1). At that time, the economy was in a shambles and the "solution" of allowing an influx of foreign money into the Wall Street economic system was discussed by the Defendants and ultimately joined in by all Defendants set forth above. The members of the Bankster Enterprise are separated in this First Amended Complaint into three groups. They are (a) The recipients of monies generated by the fraudulent ponzi/RICO scheme ("first group"), (b) enablers of monies generated by the fraudulent ponzi/RICO scheme ("second group") and (c) payors of monies generated by the scheme ("third group"). All members of each of the three groups profited by their rolls in the scheme, skimming, misappropriation and embezzlement of monies for personal use as they officially carried on the ponzi/RICO scheme. Apart from all Defendants set forth herein, Exhibit A hereto lists subsequent transferee Defendants affiliated with all Defendants herein and which may be added as Doe defendants in the future should sufficient information exist to do so. Furthermore, the actual acts and omissions of each Defendant individually - and in conspiracy with the other Defendants - are expressly set forth in this Section IV. All Defendants set forth herein acted with full knowledge that they were and are engaged in the continuing theft, laundering, misappropriation, racketeering of trillions of dollars emanating from New York City and constituting, among other things, mail fraud, wire fraud, securities fraud and TARP fraud, tax fraud as well as violations of other State and Federal laws set forth herein. To the extent the Defendant is a governmental official, they have been named in their individual capacity and each government official named herein has directed monies of American citizens into the pockets of themselves and the other Defendants set forth herein. 15. Indeed, the Defendants were so brazen that they applied to the United States Patent and Trademark Office for thousands of patents approving detailed and complex schemes - 25 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 26 of 414 PagelD #: 792 involving the movement of money, information and assets to secret entities( whether located offshore or otherwise). These applications for "patents approving of money laundering" began shortly after the millennium,and continues to this day. The patent applications make undisputed the bad-intentions of the Defendants, because they lay out the money laundering and ponzi schemes with specificity prior to the first dollar being unlawfully taken from any of the Plaintiffs or American citizens. They do this schematically in a chart prepared for the benefit of Defendant Bank of America - and filed by Bank of America's lawyers - with the United States Patent and Trademark Office during the last decade. Although it talks of "pawnbroker transactions," the patent defines "pawnbroker transactions" as including mortgage securitizations. It is an outrageous and flagrant statement of Bank of America's intention to move the money and personal financial information of hundreds of thousands of Americans overseas irrespective of whether or not it involved mortgages, securitizations, or simply thin air. 16. Each of the Defendants either filed patent applications similar to the one exhibited hereto, or they laundered money by purchasing an interest in the "general intangibles" represented by the patent application although these intangibles were and are worthless. There is no worth or value to a patent application requesting approval of a system for transferring money, yet these patent applications supported written contracts in the hundreds of dollars approving the payment of billions of dollars amongst the various Defendants and each of them. The purchase of intangibles for hundreds of millions of dollars at a time represented just one of dozens of ways that the Defendants "supported and justified" the laundering of money and supporting ponzi schemes attendant thereto. On information and belief, the Defendants and each of them are either (a) the beneficiaries of annuities provided by the Banksters pursuant to this money laundering and ponzi scheme or (b) the enablers of the offshore movement of money as expressly outlined - 26 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 27 of 414 PagelD #: 793 in the patent applications and attendant detailed money laundering schematics or (c) the payors of these annuities, skimming, misappropriating and embezzling off the top huge profits selling derivatives and other instruments supporting the very scheme that they brazenly made public during the last decade whereby they would launder, transfer, hypothecate, re-transfer, convey and fraudulently transfer the proceeds of their fraud, to wit: money and personal financial information of American citizens duped by the ponzi scheme and the fact that their entire lives (literally) were being "pawned" (in the words of one patent) internationally and without any pre- existing disclosure to Plaintiffs or other American citizens victimized by these schemes. B. Illegal Schemes of the Bankster Enterprise 17. The schemes of the Defendants are (a) described in paragraphs 1 through 5 above and (b) expanded upon in the description below. Indeed, the Defendants were so brazen in their theft, looting and governmental corruption that they have regularly, and in conspiracy with all other Defendants, fabricated evidence and then arresting lawyers who have sued them for such theft and corruption, only to then admit on witness stands in open courtrooms across the country that there is no evidence supporting their wild theories. 18. The audacious conspiratorial schemes of the Defendants reach to the highest levels of Wall Street, Main Street and State and Federal governmental agencies. Indeed, prior to the theft of their first dollar and their first dossier of private information of the Plaintiffs and other Americans, Defendants - and each of them in conspiracy with all other Defendants — applied to the United States Patent and Trademark Office seeking the approval of thousands of patents detailing complex schemes involving the movement of money, information and assets to secret entities(whether located offshore or otherwise). These applications for "patents approving - 27 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 28 of 414 PagelD #: 794 of money laundering" began shortly after the millennium, and continues to this day. The patent applications render it beyond dispute that the crimes, theft and corruption set forth herein were committed with malice aforethought, as the patents represented the Defendants' blueprint for the money laundering and theft from Plaintiffs and Americans as alleged herein. A true and correct copy of one (out of thousands) of attachments to these "smoking gun" patent applications is referenced above as a schematic submitted to the United States Patent & Trademark office by Defendant Bank of America and filed by Bank of America's lawyers with the United States Patent and Trademark Office during the last decade. Although it talks of "pawnbroker transactions," the official patent defines "pawnbroker transactions" as including mortgage securitizations. It is an outrageous and flagrant statement of Bank of America's intention to move the money and personal financial information of millions of Americans overseas irrespective of whether or not it involves mortgages, securitizations, or simply thin air. 19. Each of the Defendants either filed patent applications similar to the one referenced above, or they laundered money by purchasing an interest in the "general intangibles" represented by the patent applications although these intangibles were and are worthless. There is no worth or value to a patent application requesting approval of a system for transferring and laundering money and private information, yet these patent applications supported written contracts in the hundreds of millions of dollars approving the payment of billions of dollars amongst the various Defendants and each of them. The purchase of intangibles for hundreds of millions of dollars at a time represented just one of dozens of ways that the Defendants "supported and justified" the laundering of money and supporting ponzi schemes attendant thereto. On information and belief, the Defendants and each of them are either (a) the beneficiaries of annuities provided by the Banksters pursuant to this money laundering and ponzi - 28 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 29 of 414 PagelD #: 795 scheme or (b) the enablers of the offshore movement of money as expressly outlined in the patent applications and attendant detailed money laundering schematics or (c) the payors of these annuities, skimming, misappropriating and embezzling off the top huge profits selling derivatives and other instruments supporting the very scheme that they brazenly made public during the last decade whereby they would launder, transfer, hypothecate, re-transfer, convey and fraudulently transfer the proceeds of their fraud, to wit: money and personal financial information of American citizens duped by the ponzi scheme and the fact that their entire lives (literally) were being "pawned" (in the words of one patent) internationally and without any pre- existing disclosure to Plaintiffs or other American citizens victimized by these schemes. 20. There was never an instance when any of the Defendants intended to or did in fact credit a payment of money received by any Plaintiff herein against any amount due and owing under any promissory note signed by any Plaintiff. Rather, the scheme was the opposite: To take Plaintiffs' money and personal financial information and transfer, re-transfer, fraudulently transfer, and then reconvey all of their money and personal financial information having no relationship whatsoever with any contract existing between any of the Bankster Defendants, on the one hand, and any Plaintiff, on the other hand. Absent injunctive relief by this Court, the Bankster Defendants will continue to rob, loot, and steal Plaintiffs' assets whether through corruption and fraud (e.g., robo-signing or fabricating evidence to continue the scam) or through some other unlawful mechanism. The Executive and Legislative branches of government have paid $43 Trillion to Defendants, without being able to slow them down in any way from the robbing and looting of America. Only through judicial intervention and injunctive relief - as outlined below - can Defendants be stopped from violating the United States Patriot Act as well as the Racketeer Influenced and Corrupt Organizations Act in their organized, pre-planned - 29 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 30 of 414 PagelD #: 796 assault upon the properties, privacy and liberty interests of Plaintiffs and other American citizens. C. Twenty Trillion Dollars of TARP and Other U.S. Monies Laundered 21. In the course of their ponzi scheme - and as a result of world market conditions - Defendant Bankster Enterprise comprised all of the National Banking Enterprises set forth below and certain of its individuals. At that time, members of the Enterprise had - as a general rule - only one kind of asset securing the money they had advanced, to wit: Land. Like any ponzi scheme, they needed more money to operate and they did not have it ready. At this time, the Defendant National Banks - Bank of America, J. P. Morgan Chase, Citigroup, Citibank and various affiliate defendants in existence at the time - "melted down" before the world's eyes. Public markets crashed and certain persons trading the derivatives of the scheme went out of business or were on the verge. An example of a Bankster Defendant who failed is Bear Stearns. Bankster defendants Citigroup and Merrill Lynch were insolvent at the time Bear Stearns failed. The true head of the TARP program at this time, was private Bankster Defendant Robert Rubin who acted as the Chairman of Citigroup throughout this period and was the secret mastermind behind the TARP program at its inception as well as one of many "puppeteers" of Defendant Timothy Geitner. 22. Using the foregoing as a backdrop, the Bankster Defendants approached the United States of America at various times from 2008 through the date of this filing and garnered advances of $23 Trillion from the United States of America while concealing from it the foreign unsourced money and its owners that the Defendants were protecting. At that time, representatives of the United States of America caused the U.S.A. to advance several hundred billion dollars to these entities. - 30 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 31 of 414 PagelD #: 797 23. However, the foregoing advances were not sufficient for the Bankster Defendants because the ponzi/RICO scheme needed far more money to operate. Furthermore, the Defendants, and each of them, attempted to unlawfully profit from the turmoil while they sustained it. As a consequence several Defendants including Eric Holder, Anthony West, Robert Rubin, Timothy Geitner, Anita Dunn, Robert Bauer, and Valerie Jarrett entered the conspiracy under the following agreement with the Defendants: These individuals would cause various governmental agencies and the Fed to advance an additional $20 Trillion to the Defendants with "a wink and a nod," in exchange for obtaining for them and their closest friends a piece of the illegal profits of the ponzi/RICO scheme. Some of these monies were advanced under the so- called TARP programs and some of these monies were advanced sub silentio. 24. By April 14, 201 1 , staff members of the Office of the Controller and FDIC - United States of America - knew that the foregoing activities by the Defendants were unsound and unsafe. They confronted the Defendants and were met with additional newly elected government officials and reconstituted corporate heads of Bankster Defendants. Instead of repaying the $23 Trillion owed at the time, the Defendants concealed the ponzi/RICO scheme and the money laundering enterprise and plan of the Defendants and requested additional monies in the sub silentio manner insisted upon by the Defendants when using the Fed as their own pocket book as was done here. At the time that he became titular Treasury Secretary, puppeteer Timothy Geitner was formerly the titular Head of the New York Fed. From April 14, 201 1 until the date of this filing, on information and belief, the Defendants and each of them have (a) caused to be printed from the Fed, $20 Trillion of U.S. dollars under cover of darkness and advanced it to Defendants and (b) skimmed, misappropriated and stole monies for themselves personally as well as their families and associates in the Obama Administration as well as the - 31 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 32 of 414 PagelD #: 798 Banksters, which were then fraudulently conveyed and money laundered through the patented schemes of the Banksters in foreign countries. 25. As the public nationwide began to look with disbelief at this ponzi/RICO scheme and program - and its impact upon Plaintiffs and the American citizenry - Defendants made a concerted effort to trump-up charges against Plaintiffs and/or their clients. The object of the exercise was concealed and then implemented by governmental or quasi-governmental Defendants like Eric Holder, Tony West, Kamala Harris, Peter Krause, Thomas Layton, Joseph Dunn, Howard Miller, Anita Dunn, Robert Bauer, Scott Drexel (collectively the "Holder-Dunn Group"). Discovery is continuing. Plaintiffs will amend this complaint accordingly as additional corrupt members of the Holder-Dunn Group are located who have stolen money from the Fed whilst they fabricated evidence against those trying to stop them. The effect in many instances was to stifle any questioning of their actions pursuant to the racketeering plan by Defendants, and each of them (operating through the conspiracy set forth herein), including, but not limited to, conducting lawless activities, illegal searches and seizures, fabricating documents, paying off witnesses, suborning perjury, and conducting other activities pursuant to the unlawful RICO enterprise in violation of State and Federal law including, but not limited to, (a) preparing bogus governmental reports regarding the matter, (b) fabricating evidence against various adversaries nationwide, (c) working hand in hand with the Bankster Defendants - Defendants, and each of them - to continue the ponzi/RICO scheme and money laundering enterprises and (d) for their own benefit, taking money personally or directing it to private entities to control so that they too For purposes of this First Amended Complaint, the term "skimmed" includes misappropriating, embezzling, stealing or otherwise taking money under false pretenses and actual fraud occurring in connection with the RICO and money laundering schemes set forth herein. - 32 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 33 of 414 PagelD #: 799 could profit from the largest ponzi/RICO scheme and the largest money laundering scheme in world history. By this time, all Defendants were involved in a detailed way with the schemes described above and the involvement was active and with full knowledge of its illegality as set forth herein. D. The Nixonian Enemies' List of the Qbama Administration 26. Pursuant to the racketeering and laundering schemes set forth above, the Bankster Defendants - operating through their co-conspirators in governmental positions of law enforcement - directed the Obama Administration and parallel State Administrations who were willing to "play along" to maintain and keep current on a daily basis an "enemies list and all of their activities " so that the racketeering and laundering schemes set forth in detail above could be used with the imprimatur of "governmental oversight" through the Holder-Dunn Group and their affiliates. This has resulted in numerous cases where the Holder-Dunn Group and their affiliates - or those acting on their behalf - have admitted to extrinsic fraud, suborning perjury, attempting to fix cases, fabricating evidence and directing the use of prosecutorial governmental resources in an unequal, vindictive and selective way in which innocent people and home owners nationwide have been targeted. This is how the "robo-signing" kinds of scandals began, and is why no prosecutions of such document fabricators and forgery recidivists ever occurred. Far from being isolated as one example of unlawful conduct toward those on the enemies list, the Holder-Dunn Group has presided over the highest level of warrantless searches, seizures, wiretaps and creations of sham files and sham court filings and sham recordations and sham (so- called phantom) litigations, in the history of all United States administrations before them. - 33 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 34 of 414 PagelD #: 800 27. As of the date of filing of this First Amended Complaint, the enemies list held by the Holder-Dunn Group, their affiliates and agents and representatives - and thus subject to the foregoing illegal behavior and obstruction of justice — have included (but are not limted to): Among others, on information and belief, including in the federal enemies list supervised by the Holder-Dunn Group as set forth above are (a) Ruppert Mudock, (b) Roger Ales, (c) Fox News Network and their affiliates, agents and those acting on their behalf, (d) active members of various faith based organizations located within the jurisdictional purview of this Court in at least Brooklyn New York; and (e) active members of various faith based organizations located elsewhere in the United States (e.g, Iowa) but damaged by the fraud, theft and racketeering enterprise of Defendants in New York set forth herein; and (d) active members of various faith based organizations that openly support the United States of America's pre-2009 stance on the unwavering support of the State of Israel and against all enemies thereof including, e.g., Iran, located in Brooklyn, New York; and (f) outspoken journalists and former agents of the Holder- Dunn Group such as (g) Neil Barofsky, (h) Shiela Bair, (i) Senator Grassley, (j) Congressman Darryl Issa, (k) Sheldon Adelson, (1) Donald Trump, (m) Steve Wynn, (n) Congressman Allen West and the Tea Party, (o) Karl Rove and his affiliated entities, (p) the Koch Bros., (q) Sean Hannity, (r) Michelle Malkin, (s) James N. Fiedler, (t) Rush Limbaugh, (q) Tucker Carlson, (r) various organizations with agendas contrary to those of the Bankster Defendants as set forth in detail above, including the Daily Caller and Judicial Council Watcher and their affiliated entities. This has devastated the Plaintiffs because the Holder-Dunn Group, et al. have diverted monies and resources due Plaintiffs and their privies away from crediting such payments against mortgage balances and loan modifications; and alternatively in favor of perpetuating the money laundering and RICO schemes set forth in this complaint. - 34 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 35 of 414 PagelD #: 801 E. The New York Genesis of the Bankster Enterprise 29. In addition to the detailed jurisdictional and venue oriented facts set forth above, the racketeering and money laundering scheme outlined in detail throughout this complaint had as its only epicenter: i. The Initial Money 30. On information and belief, the first money utilized in connection with the criminal RICO enterprise set forth above, was laundered and additional money added thereto, from and with the full use of all resources located at the physical location of the Federal Reserve situated at 33 Liberty Street New York, NY. ii Continual Influx of RICO Enterprise Money 31. All the monies involved or appertaining to the RICO enterprise set forth above - from and after its inception and up to and including the date of filing of this complaint - including, but not limited, terrorist money, monies to evade the Iranian Embargo Act, drug cartel money, unsourced money, and money utilized to evade taxes, was placed into or through the clearinghouse systems in New York (including the Depositary Trust Corporation) located at 150 E. 52 nd Street, New York, NY and multiple other locations surrounding New York including the covert location in midtown Manhattan as revealed by the New York Times on December 11, 2010. iii. Other Locations 32. There are no other locations besides the New York venues set forth above, where the RICO and laundering schemes set forth herein were in fact conducted and implemented. - 35 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 36 of 414 PagelD #: 802 Without the New York locations set forth above - and all Defendants voluntary exposure to the benefits of the New York money center bank system, the RICO and money laundering schemes whereby $43 trillion shall be recovered by a receiver in this action - the RICO and money laundering schemes could not have occurred. Furthermore, as set forth above, all records proving the monetary realities of the $43 trillion money laundering enterprise are physically located in safe deposit boxes and under-carriages as set above according to proof. F. The Misappropriating of Laundering Money for Personal Use of Banksters i. In excess of $590 Million Skimmed by the Tony West/Kamala Harris Syndicate 33. As the ponzi/RICO/laundering scheme continued, it - as with all such schemes - involved a sum of money growing continually larger to support an ever-larger array and cast of criminals and characters. This allowed persons in positions of power to fall victim of the kinds of corruption existing throughout human history. Unfortunately, here, the level of corruption and concomitant theft was and continues to be unprecedented for the reasons set forth in detail above. 34. As a result thereof, a syndicate that became known as the Tony West/Kamala Harris syndicate - because of their familial relationship - took for their own personal use and the use of other Defendants who were members of the syndicate on a nationwide basis according to proof the sum of at least $590 million ($590,000,000.00). All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of this Tony West/Kamala Harris Syndicate. ii. In excess of $500 Million Skimmed by the Holder and George Syndicate 35. As a result thereof, a syndicate that became known as the Holder and George Syndicate - because of their business and personal relationship - took for their own personal use - 36 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 37 of 414 PagelD #: 803 and the use of other Defendants who were members of the syndicate on a nationwide basis according to proof the sum of at least $500 million ($500,000,000.00). All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of this Holder and Geroge Syndicate. iii. In excess of $750 Million Skimmed to Sandor Samuels & Affiliates 36. As a result thereof, a syndicate that became known as the Sandor Samuel & Affiliates syndicate - because of their business relationship - took for their own personal use and the use of other Defendants who were members of the syndicate on a nationwide basis according to proof the sum of at least $750 million ($750,000,000.00). All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of this Sandor Samuel Affiliates syndicate. iv. In excess of $780 Million Skimmed by Jeremy Ben- Ami, J Street & Affiliates, and Howard Dickstein ("The Dickstein Group") 37. As a result thereof, a syndicate that became known as the Jeremy Ben-Ami, J Street & Affiliates, and Howard Dickstein ("The Dickstein Group") - because of their business relationship and numerous controversial policy agendas - took for their own personal use and the use of other Defendants who were members of the syndicate on a nationwide basis according to proof the sum of at least $780 million ($780,000,000.00). All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of The Dickstein Group's money grab. v. In excess of $120 Million Skimmed by Robert Rubin 38. As a result thereof, a syndicate that became known as being run by Robert Rubin for himself and other Defendants according to proof. Because Mr. Rubin knew of impending - 37 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 38 of 414 PagelD #: 804 disaster resulting from the RICO and money laundering enterprises set forth herein, he engaged in a personal money grab of at least $120 million at the same time he was directing the activities of Timothy Geitner to raid the Fed and thus support the enterprise. On information and belief, puppeteer Geitner received some of this money. All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of The Dickstein Group's money grab. vi. In excess of $510 Million Skimmed by Jon Corzine Syndicate 39. As a result thereof, a syndicate that became known as the Jon Corzine Syndicate ("Corzine Syndicate") was formed in conspiracy with all Defendants for purposes of assuring that silence was purchased from all Banksters wishing to resign their positions during the largest money laundering scheme in United States history. On information and belief, one such Defendant receiving money under this Corzine-controlled syndicate is disgraced former Citigroup Chairman Defendant Vickram Pandit. On information and belief, another such Defendant receiving money under this Corzine controlled syndicate is disgraced former Bank of America Chairman Kenneth Lewis. All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of The Corzine money grab. vii. In excess of $100 Million Skimmed by Girardi-George- Rothenberg Syndicates 40. As a result thereof, a syndicate that became known as the Girardi-George- Rothenberg Syndicates ("GGR Syndicates") was formed in conspiracy with all Defendants, and with the assistance of the family of George for purposes of assuring continuing of corruption in connection with judicial proceedings nationwide. The GGR Syndicates - in connection with several different operations conducted by them - laundered and skimmed for their own use the - 38 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 39 of 414 PagelD #: 805 sum of at least $100 million. On information and belief, Defendants Huvelle, Joseph Dunn, Thomas Layton, Howard Miller, Douglas Winthrop and/or Bill Wardlaw have participated in the skimming operations conducted by GGR Syndicates. All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of The GGR operations set forth herein. viii. In excess of $420 Billion Skimmed by the Geitner Syndicate 41. As a result thereof, a syndicate that became known as the Geitner Syndicate ("Geitner Syndicate") was formed in conspiracy with all Defendants for purposes of assuring that use of governmental resources - as directed by others in governmental positions of ultimate power - could be used for personal gain in the total sum of $420 billion. On information and belief, Defendants receiving money under this Geitner operation were and are Robert Rubin, Valerie Jarrett, Anita Dunn, Robert Bauer, persons resident in, or hailing from, Chicago and closely aligned with the Obama campaign. All Defendants in this complaint acted in conspiracy, and as agent and assign and on behalf of, each other Defendant in this complaint to protect the privacy and secrecy of The Geitner Syndicate. V. THE PARTIES: A. Plaintiffs 42. Plaintiff DONNA ABEEL is a resident of the State of California and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 herein). 43. Plaintiff DONNA DILLS is a resident of the State of New Hampshire and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 2 herein). - 39 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 40 of 414 PagelD #: 806 44. Plaintiff FRANCIS TALBOT is a resident of the State of New Hampshire and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 3 herein). 45. Plaintiff ROBERT ROCKWOOD is a resident of the State of New Hampshire and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 4 herein). 46. Plaintiff DOUG SCHMIDT is a resident of the State of Minnesota and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 5 herein) 47. Plaintiff DAVE SCHMIDT is a resident of the State of Minnesota and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 6 herein) 48. Plaintiff DALE SCHMIDT is a resident of the State of Minnesota and had mortgage loans with one or more of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 7 herein) 49. Plaintiff RICK ADAMS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 8 herein.) 50. Plaintiff ROBERT AKASHI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 7 herein.) 51. Plaintiff JIMMY ALAURIA is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff - 40 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 41 of 414 PagelD #: 807 shall be designated as Plaintiff No. 8 herein.) 52. Plaintiff DEBBIE EDITH ALEGRIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 9.) 53. Plaintiff IZAIDA ALTAMIRANO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 10.) 54. Plaintiff ROBERTA ALVAREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 11.) 55. Plaintiff PATRICIA ALVERT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 12.) 56. Plaintiff FATEVIA APONTE is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 13.) 57. Plaintiff MANUEL ARECHIGA JR is a resident of the State of Texas and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 14.) 58. Plaintiff SCOTT ARMSTRONG is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 15.) - 41 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 42 of 414 PagelD #: 808 59. Plaintiff LAURA AUPPERLE is a resident of the State of Michigan and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 16.) 60. Plaintiff JOSE P. AY ALA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 17.) 61. Plaintiff ALEX BACARON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 18.) 62. Plaintiff WILLIAM BARBER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 19.) 63. Plaintiff PHILIP BARR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 20.) 64. Plaintiff FRANCISCO BARRIOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 21.) 65. Plaintiff TOM BEINAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 22.) - 42 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 43 of 414 PagelD #: 809 66. Plaintiff ANDREW BELCHER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 23.) 67. Plaintiff MIRTHA BERNES is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 24.) 68. Plaintiff NASSAR BEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 25.) 69. Plaintiff MARK BLANCO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 26.) 70. Plaintiff JOHN BOBEK is a resident of the State of Hawaii and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 27.) 71. Plaintiff ELINOR BOZZONE is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 28.) 72. Plaintiff LAWRENCE BRACCO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 29.) - 43 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 44 of 414 PagelD #: 810 73. Plaintiff NATHAN BREHM is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 30.) 74. Plaintiff KIM BRIDGES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 31.) 75. Plaintiff MIKE BRIGGS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 32.) 76. Plaintiff ERENSTrNE BRrNKLEY is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 33.) 77. Plaintiff VICKIE BROCK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 34.) 78. Plaintiff DEXTER BROWN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 35.) 79. Plaintiff DIANE BROWN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 36.) - 44 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 45 of 414 PagelD #: 811 80. Plaintiff LINDA BURGER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 37.) 81. Plaintiff BONNIE BUTTERWORTH is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 38.) 82. Plaintiff JESSICA CABASAL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 39.) 83. Plaintiff CARLA CALER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 40.) 84. Plaintiff PAUL CAMPAGNA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 41.) 85. Plaintiff HARRY CAMPBELL is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 42.) 86. Plaintiff IRENE CARDENAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 43.) - 45 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 46 of 414 PagelD #: 812 87. Plaintiff MARIA CARINO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 44.) 88. Plaintiff JON CARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 45.) 89. Plaintiff DINORAH CARMENATE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 46.) 90. Plaintiff JUAN CARRTLLO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 47.) 91. Plaintiff JAQUELINE CARROLL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 48.) 92. Plaintiff JOSE Z. CASTRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 49.) 93. Plaintiff PAUL CATER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 50.) - 46 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 47 of 414 PagelD #: 813 94. Plaintiff ELOY CERTEZA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 51.) 95. Plaintiff GEOFFREY CHARLTON is a resident of the State of Georgia and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 52.) 96. Plaintiff MARK CHASTEEN is a resident of the State of Texas and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 53.) 97. Plaintiff VIPIN CHATURVEDI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 54.) 98. Plaintiff RAQUEL CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 55.) 99. Plaintiff RFTO CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 56.) 100. Plaintiff ANTONIO CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 57.) - 47 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 48 of 414 PagelD #: 814 101. Plaintiff KEVIN CHEEK is a resident of the State of Minnesota and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 58.) 102. Plaintiff WILLIAM CHIN is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 59.) 103. Plaintiff MEHRDAD CHITSAZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 60.) 104. Plaintiff HECTOR CIBRIAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 61.) 105. Plaintiff REN ATA CfRCEO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 62.) 106. Plaintiff ELIZABETH CLAMPET is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 63.) 107. Plaintiff STEPHEN CLARKE is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 64.) - 48 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 49 of 414 PagelD #: 815 108. Plaintiff CHRISTOPHER COCKRELL is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 65.) 109. Plaintiff DANIELLE COCKRELL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 66.) 1 10. Plaintiff GEOFFREY COCKRELL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 67.) 111. Plaintiff LUISE COHEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 68.) 112. Plaintiff OLGA L. COLLAZO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 69.) 113. Plaintiff ROLANDO COLLAZO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 70.) 114. Plaintiff ARTEMIO CONCEPCION is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 71.) - 49 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 50 of 414 PagelD #: 816 115. Plaintiff KAT CONWAY is a resident of the State of Hawaii and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 72.) 116. Plaintiff RUTH CORONA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 73.) 117. Plaintiff LUIS COSIO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 74.) 118. Plaintiff PATRICIA CRESPO is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 75.) 1 19. Plaintiff MARGO CRUZ is a resident of the State of New Mexico and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 76.) 120. Plaintiff MARIA CRUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 77.) 121. Plaintiff OCTAVIO CRUZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 78.) - 50 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 51 of 414 PagelD #: 817 122. Plaintiff WILLIAM CUBIAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 79.) 123. Plaintiff JOSE CUESTA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 80.) 124. Plaintiff DONNA DALTON is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 81.) 125. Plaintiff MARIA DE LA PAZ JIMENEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 82.) 126. Plaintiff LOURDES RUIZ DE LA TORRE is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 83.) 127. Plaintiff CELON D. DENNIS is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 84.) 128. Plaintiff DOUGLAS DENT is a resident of the State of Alabama and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 85.) - 51 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 52 of 414 PagelD #: 818 129. Plaintiff CHRISTIAN DIAZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 86.) 130. Plaintiff MARTHA DIAZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 87.) 131. Plaintiff NICHOLAS DIETEL is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 88.) 132. Plaintiff JEFFREY DIXON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 89.) 133. Plaintiff IRA DORFMAN is a resident of the State of Maryland and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 90.) 134. Plaintiff PATRICIA DOWLfNG is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 91.) 135. Plaintiff DANIEL DWYER is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 92.) - 52 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 53 of 414 PagelD #: 819 136. Plaintiff JAMES EBLEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 93.) 137. Plaintiff GLEN ENG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 94.) 138. Plaintiff PATRICIA ESPINOSA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 95.) 139. Plaintiff ALICIA FAJARDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 96.) 140. Plaintiff CLOVIS FEARON is a resident of the State of Pennsylvania and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 97.) 141 . Plaintiff ALBERTINA FIGUEROA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 98.) 142. Plaintiff ROBERTO FIGUEROA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 99.) - 53 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 54 of 414 PagelD #: 820 143. Plaintiff JOSEPH FITZGERALD is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 100.) 144. Plaintiff CAROL FLEMMING is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 101.) 145. Plaintiff COREY FLINN is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 102.) 146. Plaintiff LEONARDO FLORES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 103.) 147. Plaintiff ALAN FOGELSTROM is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 104.) 148. Plaintiff NORMA FOGELSTROM is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 105.) 149. Plaintiff DONNA FOOTE is a resident of the State of Connecticut and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 106.) - 54 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 55 of 414 PagelD #: 821 150. Plaintiff JULIE FRALEY is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 107.) 151. Plaintiff DENNIS FROST is a resident of the State of Wyoming and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 108.) 152. Plaintiff CHRISTOPHE FRUCTUS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 109.) 153. Plaintiff SUSAN GALLAGHER is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 10.) 154. Plaintiff LIDIA GARCIA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 111.) 155. Plaintiff SJJVIONA GARCIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 12.) 156. Plaintiff JOE GARCIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 13.) - 55 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 56 of 414 PagelD #: 822 157. Plaintiff TRACI GEHM is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 114.) 158. Plaintiff PHILLIP GENOVESE is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 15.) 159. Plaintiff BARBARA GIBBS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 116.) 160. Plaintiff JAMES GILBERT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 117.) 161. Plaintiff BRADLEY GIPOLAN is a resident of the State of Hawaii and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 118.) 162. Plaintiff DENNIS GLEASON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 1 19.) 163. Plaintiff TOMMY GLOVER is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 120.) - 56 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 57 of 414 PagelD #: 823 164. Plaintiff CARLOS GONZALES is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 121.) 165. Plaintiff MARIA GONZALES is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 122.) 166. Plaintiff NELSON A. GONZALEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 123.) 167. Plaintiff NELSON J. GONZALEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 124.) 168. Plaintiff CHRISTOPHER GROSSMAN is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 125.) 169. Plaintiff DIANE GRUBIC is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 126.) 170. Plaintiff WALTER GRUBIC is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 127.) - 57 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 58 of 414 PagelD #: 824 171. Plaintiff NESTOR GUILLEN is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 128.) 172. Plaintiff WILLIAM GUTIERREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 129.) 173. Plaintiff ENRIQUE GUZMAN is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 130.) 174. Plaintiff MAGA GUZMAN is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 131.) 175. Plaintiff MARIA GUZMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 132.) 176. Plaintiff ALLISON HANSON is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 133.) 177. Plaintiff JOHN HANSON is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 134.) - 58 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 59 of 414 PagelD #: 825 178. Plaintiff THOMAS HERBST is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 135.) 179. Plaintiff JORGE L. HERNANDEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 136.) 180. Plaintiff MARCELLA HERNANDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 137.) 181. Plaintiff MIGUEL HERNANDEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 138.) 182. Plaintiff DAVID HERRON is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 139.) 183. Plaintiff SESSING HEWITT is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 140.) 184. Plaintiff LISA HIGGENS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 141.) - 59 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 60 of 414 PagelD #: 826 185. Plaintiff NANCY HOLCOMBE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 142.) 186. Plaintiff VIRGINIA HOSKTNG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 143.) 187. Plaintiff VINCE HUBBARD is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 144.) 188. Plaintiff KELVIN HURDLE is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 145.) 189. Plaintiff MICHELLE HURTADO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 146.) 190. Plaintiff ART ITURBE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 147.) 191. Plaintiff ATHENA JACKSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 148.) - 60 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 61 of 414 PagelD #: 827 192. Plaintiff MARIA DE LA PAZ JIMENEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 149.) 193. Plaintiff HARLENE JOHNSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 150.) 194. Plaintiff PORTIA JOSEPH is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 151.) 195. Plaintiff JEROME KAMINS is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 152.) 196. Plaintiff JENNIFER KAUER is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 153.) 197. Plaintiff DAN KLEIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 154.) 198. Plaintiff NANCY KRANTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 155.) - 61 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 62 of 414 PagelD #: 828 199. Plaintiff MORGAN LAWLEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 156.) 200. Plaintiff BOBBIE LEONARD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 157.) 201. Plaintiff MARK C. LILLY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 158.) 202. Plaintiff MIROSLAVA LITTERDRAGT is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 159.) 203. Plaintiff DOUGLAS LIZARDI is a resident of the State of Pennsylvania and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 160.) 204. Plaintiff DINORAH LLANES is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 161.) 205. Plaintiff ROSALINDA LOCKHART is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 162.) - 62 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 63 of 414 PagelD #: 829 206. Plaintiff THOMAS LOCKHART is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 163.) 207. Plaintiff ALAN LOCKLEAR is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 164.) 208. Plaintiff MARIA DOLORES LOMBERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 165.) 209. Plaintiff MOISES LOPEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 166.) 210. Plaintiff ANGEL LOPEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 167.) 211. Plaintiff MOISES LOPEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 168.) 212. Plaintiff DELORES LUCAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 169.) - 63 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 64 of 414 PagelD #: 830 213. Plaintiff BURT LUND is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 170.) 214. Plaintiff MAE LUND is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 171.) 215. Plaintiff ALEJANDRO LUZARDO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 172.) 216. Plaintiff RONNIE LYLES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 173.) 217. Plaintiff BRYAN LYNCH is a resident of the State of Texas and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 174.) 218. Plaintiff JOSEPH K LYONS is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 175.) 219. Plaintiff BRUCE MACBRIDE is a resident of the State of Idaho and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 176.) - 64 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 65 of 414 PagelD #: 831 220. Plaintiff ANITA MACHADO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 177.) 221. Plaintiff TANYA MACHADO is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 178.) 222. Plaintiff STELLA MARKLEY is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 179.) 223. Plaintiff TERESA MARQUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 180.) 224. Plaintiff LUIS MARTINEZ is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 181.) 225. Plaintiff PATRICK MARTINEZ is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 182.) 226. Plaintiff CHARLOTTE MCARDLE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 183.) - 65 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 66 of 414 PagelD #: 832 227. Plaintiff SAOVANNI MEAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 184.) 228. Plaintiff DANIEL MELENDEZ is a resident of the State of Oregon and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 185.) 229. Plaintiff GLORIA MELO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 186.) 230. Plaintiff MARGARITA MILAM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 187.) 231. Plaintiff MARIE MILLER is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 188.) 232. Plaintiff AARON MIR is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 189.) 233. Plaintiff ARLYN MIR is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 190.) - 66 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 67 of 414 PagelD #: 833 234. Plaintiff JASON MOEDING is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 191.) 235. Plaintiff VERONICA MONTERRUBIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 192.) 236. Plaintiff ERIK MUMFORD is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 193.) 237. Plaintiff ANTONIO MUNOZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 194.) 238. Plaintiff CARMEN MUNOZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 195.) 239. Plaintiff CINDY MURRILLO is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 196.) 240. Plaintiff JUAN CARLOS MURRILLO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 197.) - 67 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 68 of 414 PagelD #: 834 241. Plaintiff JOE NAVARRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 198.) 242. Plaintiff CRISTINA NAVARRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 199.) 243. Plaintiff MICAH NEELY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 200.) 244. Plaintiff RICHARD NEELY is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 201.) 245. Plaintiff JONIQUE GARCIA is a resident of the State of Connecticut and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 202.) 246. Plaintiff ERNESTO NEPOMUCENO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 203.) 247. Plaintiff CATHERINE NUTT is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 204.) - 68 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 69 of 414 PagelD #: 835 248. Plaintiff SENEN OCHOA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 205.) 249. Plaintiff TALIA OLIVERA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 206.) 250. Plaintiff CHRISTINA ORNELAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 207.) 251. Plaintiff KAROL OUSLEY is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 208.) 252. Plaintiff FRANK PACHECO is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 209.) 253. Plaintiff ARMANDO PADILLA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 210.) 254. Plaintiff ANGELA PARADA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 211.) - 69 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 70 of 414 PagelD #: 836 255. Plaintiff RUBEN PARRA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 212.) 256. Plaintiff EUGENE PATERRA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 213.) 257. Plaintiff ALTINA PATRICK is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 214.) 258. Plaintiff ROLAND PERKINS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 215.) 259. Plaintiff RAUL PERNETT is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 216.) 260. Plaintiff MICHAEL PHILLIPS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 217.) 261. Plaintiff LESLIE POLLACK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 218.) - 70 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 71 of 414 PagelD #: 837 262. Plaintiff THOMAS POUPARD is a resident of the State of Michigan and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 219.) 263. Plaintiff CARTER POWELL is a resident of the State of Oregon and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 220.) 264. Plaintiff MERY QUINTANA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 221.) 265. Plaintiff MERLE RAG AN is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 222.) 266. Plaintiff DANIEL RAMIREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 223.) 267. Plaintiff FRANCISCO RAMIREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 224.) 268. Plaintiff ANGELICA RAMIREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 225.) - 71 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 72 of 414 PagelD #: 838 269. Plaintiff KAIVALYA RAWAL is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 226.) 270. Plaintiff JOE REID is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 227.) 271. Plaintiff SILVIA RENDON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 228.) 272. Plaintiff JOSE REYES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 229.) 273 . Plaintiff MICHAEL RICCIARDI is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 230.) 274. Plaintiff MARJORIE RICHARDSON is a resident of the State of New Jersey and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 231.) 275. Plaintiff DAVE RICHMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 232.) - 72 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 73 of 414 PagelD #: 839 276. Plaintiff CONNIE RICOTTA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 233.) 277. Plaintiff EDDIE RIVERA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 234.) 278. Plaintiff GARY ROBERTS is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 235.) 279. Plaintiff HERMELINDO ROCHA - VARGAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 236.) 280. Plaintiff GUIDO RODRIGUEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 237.) 281. Plaintiff MARTHA RODRIGUEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 238.) 282. Plaintiff NANCY P. RODRIGUEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 239.) - 73 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 74 of 414 PagelD #: 840 283. Plaintiff PAUL RODRIGUEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 240.) 284. Plaintiff ENRIQUE ROMERO is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 241.) 285. Plaintiff MICHAEL ROMERO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 242.) 286. Plaintiff SHERRIE SAFKO is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 243.) 287. Plaintiff LILY SALAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 244.) 288. Plaintiff GUADALUPE SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 245.) 289. Plaintiff HILDA SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 246.) - 74 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 75 of 414 PagelD #: 841 290. Plaintiff JAIME SANCHEZ is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 247.) 291. Plaintiff ROGER SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 248.) 292. Plaintiff ANTONIO SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 249.) 293. Plaintiff HECTOR SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 250.) 294. Plaintiff MARIA SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 251.) 295. Plaintiff SUSAN SANDERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 252.) 296. Plaintiff RUBEN SANTIAGO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 253.) - 75 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 76 of 414 PagelD #: 842 297. Plaintiff JOSE SAUCEDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 254.) 298. Plaintiff VICKIE SCHETRITT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 255.) 299. Plaintiff ROBERT SCHMALFELDT is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 256.) 300. Plaintiff JOSE ALFREDO SEGOVIA is a resident of the State of Texas and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 257.) 301. Plaintiff SHERYL SEIM-MONTOYA is a resident of the State of Oregon and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 258.) 302. Plaintiff ARVIN SERRANO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 259.) 303. Plaintiff MARGARITA SHEA is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 260.) - 76 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 77 of 414 PagelD #: 843 304. Plaintiff KENNETH SIMONSEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 261.) 305. Plaintiff CHARLES SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 262.) 306. Plaintiff CRAYTON SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 263.) 307. Plaintiff ROBERT SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 264.) 308. Plaintiff ZENAIDA SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 265.) 309. Plaintiff JAMES SNYDER is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 266.) 310. Plaintiff VALORIE SNYDER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 267.) - 77 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 78 of 414 PagelD #: 844 311. Plaintiff ILIANA SORENSEN is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 268.) 312. Plaintiff ROSARIO MARIA SOTO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 269.) 313. Plaintiff DAVID STARKEY is a resident of the State of Tennessee and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 270.) 314. Plaintiff DEL STAUDINGER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 271.) 315. Plaintiff ANDREW STOLZ is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 272.) 316. Plaintiff PAUL STROHECKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 273.) 317. Plaintiff RICHARD STRUNK is a resident of the State of Ohio and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 274.) - 78 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 79 of 414 PagelD #: 845 318. Plaintiff LIDIA TAPIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 275.) 319. Plaintiff DELANE TARRA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 276.) 320. Plaintiff MANUEL TAVARES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 277.) 321. Plaintiff MARIA TAVARES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 278.) 322. Plaintiff ROBERT TAYLOR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 279.) 323. Plaintiff JOHN TEDESCO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 280.) 324. Plaintiff EVA THIELK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 281.) - 79 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 80 of 414 PagelD #: 846 325. Plaintiff JOS A TTRADO is a resident of the State of New Jersey and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 282.) 326. Plaintiff MAILIN TOMLINSON is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 283.) 327. Plaintiff TONY TRUJILLO is a resident of the State of New Mexico and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 284.) 328. Plaintiff JODI TUFT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 285.) 329. Plaintiff JEFF TURNER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 286.) 330. Plaintiff MALCOLM TURNER is a resident of the State of Hawaii and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 287.) 331. Plaintiff RITA UCHEKA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 288.) - 80 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 81 of 414 PagelD #: 847 332. Plaintiff HUGO URRIBARRI is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 289.) 333. Plaintiff MITCH VAN MECHELEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 290.) 334. Plaintiff HERMELINDO VARGAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 291.) 335. Plaintiff THEREISI VILLARUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 292.) 336. Plaintiff DONALD VITAK II is a resident of the State of Texas and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 293.) 337. Plaintiff MARGUERITE VITA-MATUZOLA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 294.) 338. Plaintiff GARY WAGGY is a resident of the State of Maryland and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 295.) - 81 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 82 of 414 PagelD #: 848 339. Plaintiff CARROLL WALTERS is a resident of the State of Virginia and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 296.) 340. Plaintiff ARTHUR WEAVER JR. is a resident of the State of Pennsylvania and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 297.) 341. Plaintiff TRACY WEBER is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 298.) 342. Plaintiff KENNETH WEINER is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 299.) 343. Plaintiff GUNTER WEISSMANN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 300.) 344. Plaintiff CLINT WEST is a resident of the State of Washington and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 301.) 345. Plaintiff NIKKI WHITE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 302.) - 82 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 83 of 414 PagelD #: 849 346. Plaintiff ACHINI WHITE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 304.) 347. Plaintiff MICHAEL WIEDERHOLD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 305.) 348. Plaintiff GEORGE WILCOX is a resident of the State of Pennsylvania and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 306.) 349. Plaintiff PAUL WILDER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 307.) 350. Plaintiff DEBRA WILSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 308.) 351. Plaintiff JON WITHROW is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 309.) 352. Plaintiff PETER WRIGHT is a resident of the State of Pennsylvania and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 310.) - 83 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 84 of 414 PagelD #: 850 353. Plaintiff PHILIP WRIGHT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 311.) 354. Plaintiff JAMES YOCUM is a resident of the State of Alabama and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 312.) 355. Plaintiff ALEX ZAETS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 313.) 356. Plaintiff LUIS ZAVALA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 314.) 357. Plaintiff GEORGE K. ZINK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 315.) 358. Plaintiff REBECCA ABAD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 316.) 359. Plaintiff THOMAS ADLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 317.) - 84 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 85 of 414 PagelD #: 851 360. Plaintiff BIB IAN AFABLE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 318.) 361. Plaintiff MICHAEL AKIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 319.) 362. Plaintiff SUREN ALAVERDYAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 320.) 363. Plaintiff DORA ALDRETE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 321.) 364. Plaintiff KARL AMRINE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 322.) 365. Plaintiff ELMER ANDERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 323.) 366. Plaintiff ERIC ANDERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 324.) - 85 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 86 of 414 PagelD #: 852 367. Plaintiff PAMELA ANDERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 325.) 368. Plaintiff SABRTNA ANDERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 326.) 369. Plaintiff DONALD ANDREWS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 327.) 370. Plaintiff DAVID APPEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 328.) 371. Plaintiff OLGA ARANIVA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 329.) 372. Plaintiff ANTONIO ARCTNAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 330.) 373. Plaintiff ROBERT ARRINGTON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 331.) - 86 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 87 of 414 PagelD #: 853 374. Plaintiff EWY AXELSSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 332.) 375. Plaintiff JOHN BAHURA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 333.) 376. Plaintiff GLORIA BAILEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 334.) 377. Plaintiff IRMA BAKER-PARRA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 335.) 378. Plaintiff BRUCE BARMAKIAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 336.) 379. Plaintiff RODRICK BARNETT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 337.) 380. Plaintiff KEVIN BATMAN is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 338.) - 87 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 88 of 414 PagelD #: 854 381. Plaintiff LORI BATMAN is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 339.) 382. Plaintiff DAVID BEAUBIEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 340.) 383. Plaintiff MARILYN BEAUBIEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 341.) 384. Plaintiff AMANDA BENNETT is a resident of the State of Washington and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 342.) 385. Plaintiff GEORGE BENNETT is a resident of the State of Washington and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 343.) 386. Plaintiff ANNETTE BERRY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 344.) 387. Plaintiff ROBERT BERRY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 345.) - 88 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 89 of 414 PagelD #: 855 388. Plaintiff ALVIN BLAKE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 346.) 389. Plaintiff TAW ANA BLAKE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 347.) 390. Plaintiff CAROLE BOOTH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 348.) 391. Plaintiff JOHN BOOTH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 349.) 392. Plaintiff ARACELI BOWMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 350.) 393. Plaintiff BILLY BOWMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 351.) 394. Plaintiff PATRICK PAYGAR BOYD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 352.) - 89 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 90 of 414 PagelD #: 856 395. Plaintiff BARRY BOZARTH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 353.) 396. Plaintiff ARNOLD BRIGMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 354.) 397. Plaintiff DEBORAH BRIGMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 355.) 398. Plaintiff VALERY BUBELA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 356.) 399. Plaintiff BONNIE BUCKLEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 357.) 400. Plaintiff TOBY BUTTERWORTH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 358.) 401. Plaintiff NELIDA CAMPOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 359.) - 90 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 91 of 414 PagelD #: 857 402. Plaintiff JERRY CAN AD AY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 360.) 403. Plaintiff MARIAN CANADY MEIXNER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 361.) 404. Plaintiff GEORGE CASTRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 362.) 405. Plaintiff FRANCIS CELO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 363.) 406. Plaintiff CARLOS CERVANTES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 364.) 407. Plaintiff ROSE CHANG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 365.) 408. Plaintiff JOHN CHARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 366.) - 91 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 92 of 414 PagelD #: 858 409. Plaintiff KATHERINE CHARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 367.) 410. Plaintiff DANIEL CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 368.) 411. Plaintiff JOSEPH CHAVOEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 369.) 412. Plaintiff JOSEPH CINA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 370.) 413. Plaintiff GRANT CLARK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 371.) 414. Plaintiff SONJA CLARK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 372.) 415. Plaintiff HUGH COLLINS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 373.) - 92 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 93 of 414 PagelD #: 859 416. Plaintiff SEAN COMBS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 374.) 417. Plaintiff ARTURO CONCHA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 375.) 418. Plaintiff CHERIE COOK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 376.) 419. Plaintiff DENISE COOK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 377.) 420. Plaintiff RANDALL COOK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 378.) 421 . Plaintiff BENJAMIN CORONA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 379.) 422. Plaintiff DIONICO CORTEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 380.) - 93 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 94 of 414 PagelD #: 860 423. Plaintiff BERTHA CREVOLIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 381.) 424. Plaintiff RONNIE CREVOLIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 382.) 425. Plaintiff MATTHEW CROSBIE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 383.) 426. Plaintiff CARY CRUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 384.) 427. Plaintiff ROSEMARY CRUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 385.) 428. Plaintiff HOUSTON CURTIS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 386.) 429. Plaintiff ERIC CUTLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 387.) - 94 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 95 of 414 PagelD #: 861 430. Plaintiff CHARLES DANIELS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 388.) 43 1 . Plaintiff CHRISTINA DANIELS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 389.) 432. Plaintiff RICARDO DAVALOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 390.) 433. Plaintiff CURTIS DAVIDSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 391.) 434. Plaintiff TROY DAVIS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 392.) 435. Plaintiff SARGIS DAVODDANIEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 393.) 436. Plaintiff DON DECKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 394.) - 95 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 96 of 414 PagelD #: 862 437. Plaintiff TAMMY DECKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 395.) 438. Plaintiff PAZ DIAZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 396.) 439. Plaintiff OLIC DUNNING III is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 397.) 440. Plaintiff DAVID EBADAT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 398.) 441 . Plaintiff HOTOSA EBRAHIMZADEH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 399.) 442. Plaintiff KENNETH EDGECOMBE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 400.) 443 . Plaintiff NICOLE EDGECOMBE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 401.) - 96 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 97 of 414 PagelD #: 863 444. Plaintiff MEHRDAD EMSHA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 402.) 445. Plaintiff MARTIN ESCOBEDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 403.) 446. Plaintiff YOLANDA ESCOBEDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 404.) 447 . Plaintiff ENRIQUETA ESPINOS A is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 405.) 448. Plaintiff FELIPA ESPINOS A is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 406.) 449. Plaintiff FRANCISCO ESPINOSA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 407.) 450. Plaintiff JOSE ESPINOSA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 408.) - 97 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 98 of 414 PagelD #: 864 451. Plaintiff DAVID ESTRADA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 409.) 452. Plaintiff TY ETTERLEIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 410.) 453. Plaintiff FATEMEH FADAKAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 411.) 454. Plaintiff DAVID FAULHABER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 412.) 455 . Plaintiff MICHELLE FAVAZZO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 413.) 456. Plaintiff ROGER FENSTERMACHER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 414.) 457. Plaintiff LIZETTE MILAN-FIEDLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 415.) - 98 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 99 of 414 PagelD #: 865 458. Plaintiff FUMIKO FISHER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 416.) 459. Plaintiff RICHARD FOMIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 417.) 460. Plaintiff LOURDES FONTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 418.) 461. Plaintiff WAYNE FONTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 419.) 462. Plaintiff ROGER FOSDICK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 420.) 463. Plaintiff SUSAN FRANCO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 421.) 464. Plaintiff JAMES FRASER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 422.) - 99 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 100 of 414 PagelD #: 866 465. Plaintiff JO ELLEN FRASER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 423.) 466. Plaintiff D'ANN FRIEND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 424.) 467. Plaintiff MATTHEW FRIEND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 425.) 468. Plaintiff PHILLIP GALERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 426.) 469. Plaintiff BENJAMIN GAMEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 427.) 470. Plaintiff JOSEFINA PEREZ GARCIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 428.) 471. Plaintiff ANTHONY GOLDEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 429.) - 100 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 101 of 414 PagelD #: 867 472. Plaintiff JOSEPH GOMEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 430.) 473. Plaintiff ANA GONZALEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 431.) 474. Plaintiff ESTER GONZALEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 432.) 475. Plaintiff OSCAR GONZALEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 433.) 476. Plaintiff ROBERT GRAHAM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 434.) 477. Plaintiff RONNIE GREEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 435.) 478. Plaintiff SUSANNA GREEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 436.) - 101 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 102 of 414 PagelD #: 868 479. Plaintiff GRETA GREGORIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 437.) 480. Plaintiff STEVEN GUMIENNY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 438.) 481. Plaintiff BRIAN GURNEE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 439.) 482. Plaintiff AHMAD HAKIMJAVADI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 440.) 483. Plaintiff RICHARD HALE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 441.) 484. Plaintiff JACK HALLEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 442.) 485. Plaintiff TRACEY HAMPTON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 443.) - 102 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 103 of 414 PagelD #: 869 486. Plaintiff CHERISE HANSSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 444.) 487. Plaintiff STEVEN HARD IE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 445.) 488. Plaintiff CINDY HARRISON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 446.) 489. Plaintiff JOAN HENDERSON-BROWN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 447.) 490. Plaintiff LESLIE HENDRICKS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 448.) 491 . Plaintiff RUSSEL HENDRICKS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 449.) 492. Plaintiff CENOBIO HERNANDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 450.) - 103 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 104 of 414 PagelD #: 870 493. Plaintiff LEONARD HERNANDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 451.) 494. Plaintiff MODJULITA HERNANDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 452.) 495. Plaintiff ALFREDO HERRERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 453.) 496. Plaintiff LORENA HERRERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 454.) 497. Plaintiff MARIO HERRERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 455.) 498. Plaintiff BRETT HESKETT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 456.) 499. Plaintiff RIZZA HESKETT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 457.) - 104 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 105 of 414 PagelD #: 871 500. Plaintiff RAYMOND HILL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 458.) 501 . Plaintiff ARMANDO HINOJOSA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 459.) 502. Plaintiff HEATH HODEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 460.) 503. Plaintiff SALVADOR HUIZAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 461.) 504. Plaintiff PATRICK HUNT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 462.) 505. Plaintiff JOSEPH IGNACIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 463.) 506. Plaintiff REBECCA IGNACIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 464.) - 105 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 106 of 414 PagelD #: 872 507. Plaintiff CYNTHIA IRELAND is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 465.) 508. Plaintiff CLARENCE IRVING is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 466.) 509. Plaintiff EVELYN IRVING is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 467.) 510. Plaintiff MUHAMMAD ISLAM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 468.) 511. Plaintiff GLEN JACKSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 469.) 512. Plaintiff HILLARY JACKSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 470.) 513. Plaintiff PAUL JACKSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 471.) - 106 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 107 of 414 PagelD #: 873 514. Plaintiff JESSE JOHNSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 472.) 515. Plaintiff NICHOLAS JONES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 473.) 516. Plaintiff JEAN JOSEPH is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 474.) 517. Plaintiff MARIE JOSEPH is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 475.) 518. Plaintiff GUS KATSIKIDES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 476.) 519. Plaintiff CASEY KAUER is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 477.) 520. Plaintiff JENNIFER KAUER is a resident of the State of Utah and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 478.) - 107 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 108 of 414 PagelD #: 874 521. Plaintiff JOHN KEALY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 479.) 522. Plaintiff KEVIN KEEHL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 480.) 523. Plaintiff CARLEEN KELLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 481.) 524. Plaintiff DENNIS KEMP is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 482.) 525. Plaintiff GLORY KENNISON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 483.) 526. Plaintiff LANCE KENNISON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 484.) 527. Plaintiff BARBARA KIKUGAWA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 485.) - 108 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 109 of 414 PagelD #: 875 528. Plaintiff CHRIS KIM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 486.) 529. Plaintiff JAY KIM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 487.) 530. Plaintiff LYNN KIMBERLY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 488.) 531. Plaintiff LOUIS KLEIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 489.) 532. Plaintiff HARKRISHNAN KOCHAR is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 490.) 533. Plaintiff JASPAL KOCHAR is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 491.) 534. Plaintiff BRENT KOMOUROUS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 492.) - 109 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 110 of 414 PagelD #: 876 535. Plaintiff DEAN KRAEMER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 493.) 536. Plaintiff JOSHUA KREITZER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 494.) 537. Plaintiff KATHRYN T. KREITZER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 495.) 538. Plaintiff PETE KREUZER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 496.) 539. Plaintiff MAZLINA LAI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 497.) 540. Plaintiff STEPHANIE LANDEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 498.) 541. Plaintiff JENNIFER LANGLO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 499.) - 110 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 111 of 414 PagelD #: 877 542. Plaintiff ASHLEY LARSEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 500.) 543. Plaintiff CHRISTIAN LARSEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 501.) 544. Plaintiff BRUCE LAWSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 502.) 545. Plaintiff TRAVIS LEAGE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 503.) 546. Plaintiff LISA LEFEBVRE is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 504.) 547. Plaintiff RAYMOND LEFEBVRE is a resident of the State of Arizona and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 505.) 548. Plaintiff JACK LEFLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 506.) - Ill - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 112 of 414 PagelD #: 878 549. Plaintiff JOELLA LEFLER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 507.) 550. Plaintiff JACQUELYNN LEONARDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 508.) 551. Plaintiff CARMEN LINARES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 509.) 552. Plaintiff LUIS LINARES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 510.) 553. Plaintiff ED LIZARDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 511.) 554. Plaintiff LINDA LIZARDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 512.) 555. Plaintiff CHERYL LOCEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 513.) - 112 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 113 of 414 PagelD #: 879 556. Plaintiff LAUREN LOCEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 514.) 557. Plaintiff DANILO LUQUIAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 515.) 558. Plaintiff YOLINA LUQUIAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 516.) 559. Plaintiff JOHN MACIAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 517.) 560. Plaintiff LOUIS MAGES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 518.) 561. Plaintiff PATRICIA MAGES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 519.) 562. Plaintiff STEFAN MAHALEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 520.) - 113 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 114 of 414 PagelD #: 880 563. Plaintiff HEATHER MAHONEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 521.) 564. Plaintiff DENIS E MANRIQUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 522.) 565. Plaintiff LAURIE MARINO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 523.) 566. Plaintiff EDUARDO MARQUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 524.) 567. Plaintiff ELNORA MARSHALL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 525.) 568. Plaintiff BRUNO MARTINEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 526.) 569. Plaintiff FRANK MARTINEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 527.) - 114 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 115 of 414 PagelD #: 881 570. Plaintiff MELANDO MARTINEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 528.) 571. Plaintiff MIKE MARTINEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 529.) 572. Plaintiff ELIZABETH MATSIK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 530.) 573. Plaintiff CALVIN MATTHEWS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 531.) 574. Plaintiff ELIZABETH MCCULLOUGH is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 532.) 575. Plaintiff SEAN MCDONALD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 533.) 576. Plaintiff MARY MEDINA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 534.) - 115 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 116 of 414 PagelD #: 882 577. Plaintiff DAVID MEDLIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 535.) 578. Plaintiff BRUCE MILLIGAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 536.) 579. Plaintiff RENE MINNAAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 537.) 580. Plaintiff RABIA MIR is a resident of the State of Connecticut and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 538.) 581. Plaintiff MARIA MIRANDA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 539.) 582. Plaintiff TOBY MOORE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 540.) 583. Plaintiff LEONIDES MORALES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 541.) - 116 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 117 of 414 PagelD #: 883 584. Plaintiff ERICA MORGERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 542.) 585. Plaintiff PETE MORGERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 543.) 586. Plaintiff BASHEER MURAD is a resident of the State of Idaho and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 544.) 587. Plaintiff CAAMIE MURAD is a resident of the State of Idaho and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 545.) 588. Plaintiff VALLIUR NADU is a resident of the State of Michigan and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 546.) 589. Plaintiff HIROSHI NAKAYAMA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 547.) 590. Plaintiff YOLANDA NATIVE) AD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 548.) - 117 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 118 of 414 PagelD #: 884 591. Plaintiff MARIA NAVARRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 549.) 592. Plaintiff OSCAR NAVARRO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 550.) 593. Plaintiff ALAN NESS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 551.) 594. Plaintiff SANDRA NESS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 552.) 595. Plaintiff DIANA NEWSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 553.) 596. Plaintiff RALPH NEWSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 554.) 597. Plaintiff ANNA NGUYEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 555.) - 118 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 119 of 414 PagelD #: 885 598. Plaintiff MICHELLE NUNIES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 556.) 599. Plaintiff JOHN OCAMPO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 557.) 600. Plaintiff NOEL OLIVARES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 558.) 601. Plaintiff ROMAN OLIVOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 559.) 602. Plaintiff MELISSA OWEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 560.) 603. Plaintiff MICHAEL OWEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 561.) 604. Plaintiff JOHN OXIDINE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 562.) - 119 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 120 of 414 PagelD #: 886 605. Plaintiff JUAN PADILLA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 563.) 606. Plaintiff MECIA PADILLA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 564.) 607. Plaintiff JOSE PANTO JA is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 565.) 608. Plaintiff MARIA PANTO JA is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 566.) 609. Plaintiff ALAN PARSONS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 567.) 610. Plaintiff CINDY PATELSKI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 568.) 611. Plaintiff KAZEVIIR PATELSKI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 569.) - 120 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 121 of 414 PagelD #: 887 612. Plaintiff MARIA PELCASTRE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 570.) 613. Plaintiff MARIO A. PERALTA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 571.) 614. Plaintiff RICARDO PEREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 572.) 615. Plaintiff JAMES PETERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 573.) 616. Plaintiff VIRGINIA PETERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 574.) 617. Plaintiff JOHN PHILLINGANE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 575.) 618. Plaintiff CAROL POWERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 576.) - 121 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 122 of 414 PagelD #: 888 619. Plaintiff DOUGLAS POWERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 577.) 620. Plaintiff ANNA MARIA PREZIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 578.) 621. Plaintiff REBECCA QUICK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 579.) 622. Plaintiff STEVEN QUICK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 580.) 623. Plaintiff WILLIAM RABELLO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 581.) 624. Plaintiff NOOROLLAH RAHDAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 582.) 625. Plaintiff ELISEO RAMOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 583.) - 122 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 123 of 414 PagelD #: 889 626. Plaintiff ISRAEL RAPURI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 584.) 627. Plaintiff DINYAH REIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 585.) 628. Plaintiff NORMAN JAY REST is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 586.) 629. Plaintiff EDITHA RESTAURO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 587.) 630. Plaintiff DONALD REY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 588.) 631. Plaintiff NANCY RILEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 589.) 632. Plaintiff BARBARA ROBINSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 590.) - 123 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 124 of 414 PagelD #: 890 633. Plaintiff STEPHEN ROBINSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 591.) 634. Plaintiff ARTHUR RODRIGUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 592.) 635 . Plaintiff JOSE LUIS RODRIGUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 593.) 636. Plaintiff MARCIANO RODRIGUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 594.) 637. Plaintiff ETHAN ROSS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 595.) 638. Plaintiff VIRGINIA ROTRAMEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 596.) 639. Plaintiff FLORENCE SABAGQUIT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 597.) - 124 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 125 of 414 PagelD #: 891 640. Plaintiff JESSE SABAGQUIT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 598.) 64 1 . Plaintiff GUILLERMO SANCHEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 599.) 642. Plaintiff DERRICK SANDERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 600.) 643. Plaintiff CARL SANKO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 601.) 644. Plaintiff JOSEPH SANTOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 602.) 645. Plaintiff SIMON SARKISIAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 603.) 646. Plaintiff DAN SCHWARTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 604.) - 125 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 126 of 414 PagelD #: 892 647. Plaintiff BRANNON SCIANNA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 605.) 648. Plaintiff MARCIA SCIANNA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 606.) 649. Plaintiff DEBBIE SCIORTINO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 607.) 650. Plaintiff JOHN SCIORTINO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 608.) 651. Plaintiff COURTNEY SCOTT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 609.) 652. Plaintiff CRANFORD SCOTT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 610.) 653. Plaintiff SHEILA SCOTT is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 611.) - 126 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 127 of 414 PagelD #: 893 654. Plaintiff BRIAN SEXSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 612.) 655. Plaintiff PETER SHELDON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 613.) 656. Plaintiff SCOTT SHUBB is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 614.) 657. Plaintiff PAUL SIBORO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 615.) 658. Plaintiff JULIET SICSIC is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 616.) 659. Plaintiff BAYAANI SIMPLICIANO is a resident of the State of Nevada and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 617.) 660. Plaintiff BALDEV SINGH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 618.) - 127 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 128 of 414 PagelD #: 894 661. Plaintiff BALJIT SINGH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 619.) 662. Plaintiff JOANNA SINGH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 620.) 663. Plaintiff ALICE SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 621.) 664. Plaintiff CHARLEY SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 622.) 665. Plaintiff MARK SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 623.) 666. Plaintiff NIDA SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 624.) 667. Plaintiff WILLIE SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 625.) - 128 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 129 of 414 PagelD #: 895 668. Plaintiff MILTON SMITH II is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 626.) 669. Plaintiff JOANNE SNYDER-DAVIDSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 627.) 670. Plaintiff DIEP SOMMERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 628.) 67 1 . Plaintiff RICHARD SORENSEN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 629.) 672. Plaintiff HEMALATHA SOURI-PARSONS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 630.) 673. Plaintiff ROBBIN STITES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 631.) 674. Plaintiff ALINA STROUP is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 632.) - 129 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 130 of 414 PagelD #: 896 675. Plaintiff GEORGE STROUP is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 633.) 676. Plaintiff SUZANNE SUGGS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 634.) 677. Plaintiff SHY AM SUNDER is a resident of the State of Michigan and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 635.) 678. Plaintiff SALLY SYMONS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 636.) 679. Plaintiff GILDA TAHMURESZADEH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 637.) 680. Plaintiff ASHMELLEY THERVIL is a resident of the State of Florida and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 639.) 681. Plaintiff KEVIN THOMPSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 639.) - 130 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 131 of 414 PagelD #: 897 682. Plaintiff BOB TIDD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 640.) 683. Plaintiff BETTY TIMBERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 641.) 684. Plaintiff SONIKA TINKER-REIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 642.) 685. Plaintiff ANDREY TODOROV is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 643.) 686. Plaintiff ADNAN TORIAK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 644.) 687. Plaintiff ALMA TOWNSEND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 645.) 688. Plaintiff GREG TOWNSEND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 646.) - 131 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 132 of 414 PagelD #: 898 689. Plaintiff MARY JANE TUMA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 647.) 690. Plaintiff TIMOTHY TUMA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 648.) 691. Plaintiff TONY TURTURICI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 649.) 692. Plaintiff CINDY VICKERY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 650.) 693. Plaintiff WILLIAM VICKERY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 651.) 694. Plaintiff ELIAS VIEYRA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 652.) 695. Plaintiff ENRIQUE VILLANUEVA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 653.) - 132 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 133 of 414 PagelD #: 899 696. Plaintiff REBECCA VILLANUEVA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 654.) 697. Plaintiff NADIA VILLARREAL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 655.) 698. Plaintiff CHRISTOPHER VILLARUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 656.) 699. Plaintiff LINDA H. VO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 657.) 700. Plaintiff PATRICK VUONG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 658.) 701. Plaintiff LAURA WALDHEIM is a resident of the State of Alabama and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 659.) 702. Plaintiff MICHAEL WALDHEIM is a resident of the State of Alabama and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 660.) - 133 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 134 of 414 PagelD #: 900 703. Plaintiff JILL WALKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 661.) 704. Plaintiff KEVIN WALKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 662.) 705. Plaintiff ZANE WALKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 663.) 706. Plaintiff GURMEET WARAICH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 664.) 707 . Plaintiff HARJINDER WARAICH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 665.) 708. Plaintiff MELISSA WARNER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 666.) 709. Plaintiff STEPHEN WAYNE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 667.) - 134 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 135 of 414 PagelD #: 901 710. Plaintiff WALTER WEISS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 668.) 711. Plaintiff EDNA WENNTNG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 669.) 712. Plaintiff JAMIE WETZEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 670.) 713. Plaintiff JIM WETZEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 671.) 714. Plaintiff TODD WIDENER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 672.) 715. Plaintiff VERONICA WIDENER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 673.) 716. Plaintiff MELISSA WIDLUND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 674.) - 135 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 136 of 414 PagelD #: 902 717. Plaintiff TIMOTHY WIDLUND is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 675.) 718. Plaintiff CRAIG WILLIAMS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 676.) 719. Plaintiff ANN WILSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 677.) 720. Plaintiff RICHARD WILSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 678.) 721. Plaintiff EDWIN ALDANA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 679.) 722. Plaintiff AUDRENE ANN ALENCASTRE-ROBERTS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 680.) 723. Plaintiff LEPHAS BAILEY is a resident of the State of Virgina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 681.) - 136 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 137 of 414 PagelD #: 903 724. Plaintiff GURDAYAL BATNA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 682.) 725. Plaintiff KAMLESH BATNA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 683.) 726. Plaintiff DARLENE BEEKS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 684.) 727. Plaintiff JAMES BEEKS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 685.) 728. Plaintiff ANDRES BENAVIDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 686.) 729. Plaintiff EDWARD BOSTOCK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 687.) 730. Plaintiff SUZAN BRITTAN - BERGMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 688.) - 137 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 138 of 414 PagelD #: 904 731. Plaintiff CARLA CALER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 689.) 732. Plaintiff NORMAN CALER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 690.) 733. Plaintiff STEVEN CAMPANELLI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 691.) 734. Plaintiff JOSE CAMPOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 692.) 735. Plaintiff MARIA ANTONIA CAN ALES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 693.) 736. Plaintiff GERARD CANNELLA is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 694.) 737. Plaintiff MELANIE CANNELLA is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 695.) - 138 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 139 of 414 PagelD #: 905 738. Plaintiff LARRY CAPOTS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 696.) 739. Plaintiff ANDRES CARDENAS - BENAVIDEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 697.) 740. Plaintiff BRIAN CARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 698.) 741. Plaintiff JON CARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 699.) 742. Plaintiff KIMBERLY CARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 670.) 743. Plaintiff LUCY CARLSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 671.) 744. Plaintiff DAWN CARMICHAEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 672.) - 139 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 140 of 414 PagelD #: 906 745. Plaintiff KIRK CARMICHAEL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 673.) 746. Plaintiff JACQUELINE CARROLL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 674.) 747 . Plaintiff JOSEPHINA C ASELLON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 775.) 748. Plaintiff SHAWN CASSIDY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 776.) 749. Plaintiff ANTONIO CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 777.) 750. Plaintiff JOSE CHAVEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 778.) 75 1 . Plaintiff MARY CLOWNEY is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 779.) - 140 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 141 of 414 PagelD #: 907 752. Plaintiff WILLIAM CLOWNEY is a resident of the State of South Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 780.) 753. Plaintiff HUGH COLLINS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 781.) 754. Plaintiff BRENDA COPPER is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 782.) 755. Plaintiff DEAN COPPER is a resident of the State of New York and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 783.) 756. Plaintiff MARIA CRUZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 784.) 757. Plaintiff CHRISTINE DAO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 785.) 758. Plaintiff AVELINA DIZON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 786.) - 141 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 142 of 414 PagelD #: 908 759. Plaintiff HONORIO DIZON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 787.) 760. Plaintiff SANDRA DUARTE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 788.) 761 . Plaintiff JOSE DUARTE LEMUS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 789.) 762. Plaintiff ANA DUENAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 790.) 763. Plaintiff STEVEN EHLERS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 791.) 764. Plaintiff MICHELLE FAVAZZO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 792.) 765. Plaintiff WILFREDO FELICIANO is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 793.) - 142 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 143 of 414 PagelD #: 909 766. Plaintiff SALLY FIGUEIREDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 794.) 767. Plaintiff FELICIA FLORES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 795.) 768. Plaintiff CARLOS FLORES-CARRILLO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 796.) 769. Plaintiff DIANE FORSMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 797.) 770. Plaintiff CORRINE FRAYSINETTE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 798.) 771. Plaintiff ANTONIO FUENTES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 790.) 772. Plaintiff MARIA ELENA FUENTES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 791.) - 143 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 144 of 414 PagelD #: 910 773. Plaintiff VICKI FURR is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 792.) 774. Plaintiff WAYNE FURR is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 793.) 775. Plaintiff OSCAR GARCIA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 794.) 776. Plaintiff ROBERT GREGG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 795.) 777. Plaintiff MAGDALENA GUIZAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 796.) 778. Plaintiff DARLENE N. HOLLO WAY is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 797.) 779. Plaintiff RALPH HOLLOWAY is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 798.) - 144 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 145 of 414 PagelD #: 911 780. Plaintiff HARLEY HUNTER is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 799.) 781. Plaintiff JEAN HUNTER is a resident of the State of Colorado and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 800.) 782. Plaintiff GERDA HYPPOLITE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 801.) 783. Plaintiff JOSEPH IGNACIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 802.) 784. Plaintiff REBECCA IGNACIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 803.) 785. Plaintiff ROGER JAMES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 804.) 786. Plaintiff ARMANDO JIMENEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 805.) - 145 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 146 of 414 PagelD #: 912 787. Plaintiff JAVIER JIMENEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 806.) 788. Plaintiff SANDY JIMENEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 807.) 789. Plaintiff DIANE KEPLEY is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 808.) 790. Plaintiff RICHARD KEPLEY is a resident of the State of North Carolina and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 809.) 791. Plaintiff GLADYS KRANTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 810.) 792. Plaintiff RICHARD KRANTZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 811.) 793. Plaintiff DEBORAH LAMB is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 812.) - 146 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 147 of 414 PagelD #: 913 794. Plaintiff MANUEL LANDAVAZO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 813.) 795. Plaintiff SHERRIE LANDOVASO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 814.) 796. Plaintiff THEIN LAM LE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 815.) 797. Plaintiff KEN LEON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 816.) 798. Plaintiff CONSUELO LOMBERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 817.) 799. Plaintiff HILARIO LUCERO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 818.) 800. Plaintiff ADELFO MACASA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 819.) - 147 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 148 of 414 PagelD #: 914 801 . Plaintiff LEONARD A MAC AS A is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 820.) 802. Plaintiff JANET MARSHALL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 821.) 803. Plaintiff JULIO MARTINS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 822.) 804. Plaintiff ROBERTO MEDINA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 823.) 805. Plaintiff BRUCE MILLIGAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 824.) 806. Plaintiff BAHMAN MIRSHAFIEE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 825.) 807. Plaintiff FARAHNAZ MIRSHAFIEE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 826.) - 148 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 149 of 414 PagelD #: 915 808. Plaintiff KIMBERLY MITCHELL is a resident of the State of Washington and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 827.) 809. Plaintiff WILLIAM MITCHELL is a resident of the State of Washington and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 828.) 810. Plaintiff MARIA MOULES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 829.) 811. Plaintiff JOSE NARIO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 830.) 812. Plaintiff STEVEN NEWTON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 831.) 813. Plaintiff KAREN NIERHAKE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 832.) 814. Plaintiff CINDY OCHOA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 833.) - 149 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 150 of 414 PagelD #: 916 815. Plaintiff DEANA OSEGUERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 834.) 816. Plaintiff JOSE OSEGUERA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 835.) 817. Plaintiff MANUEL CASTRO PALMA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 836.) 818. Plaintiff ROMINA PAREDES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 837.) 819. Plaintiff KEN PARKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 838.) 820. Plaintiff DON PEDEN is a resident of the State of Ohio and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 839.) 821. Plaintiff SOCORRO PEREDA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 840.) - 150 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 151 of 414 PagelD #: 917 822. Plaintiff IRVING PHAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 841.) 823. Plaintiff LUZ RAMIREZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 842.) 824. Plaintiff SEYED RAZAVI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 843.) 825. Plaintiff GERALD ROBERTS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 844.) 826. Plaintiff LISA RODRIGUEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 845.) 827. Plaintiff JOSEPH R. RODRIGUEZ JR. is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 846.) 828. Plaintiff OFELIA ROMERO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 847.) - 151 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 152 of 414 PagelD #: 918 829. Plaintiff JOE SALAZAR is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 848.) 830. Plaintiff REGINALD SANTIAGO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 849.) 831. Plaintiff MICHAEL SANTOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 850.) 832. Plaintiff YVONNE SANTOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 851.) 833. Plaintiff GEORGE SEELEY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 852.) 834. Plaintiff TERRY SHAFFER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 853.) 835. Plaintiff CHERYL SHAW is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 854.) - 152 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 153 of 414 PagelD #: 919 836. Plaintiff CHRISTINE SHIPMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 855.) 837. Plaintiff JAMES SHIPMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 856.) 838. Plaintiff ANABEL SILVA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 857.) 839. Plaintiff MARTIN SILVA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 858.) 840. Plaintiff MIKE SMITH is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 859.) 84 1 . Plaintiff JONNY MARIE TORRES is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 860.) 842. Plaintiff JORGE TORRES is a resident of the State of Illinois and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 861.) - 153 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 154 of 414 PagelD #: 920 843. Plaintiff CHARLOTTE O. TUCKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 862.) 844. Plaintiff WILLIAM TUCKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 863.) 845. Plaintiff THEREISI VILLARUZE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 864.) 846. Plaintiff HUY VO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 865.) 847. Plaintiff DAVID WALLACE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 866.) 848. Plaintiff VICTORIA WALLACE is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 867.) 849. Plaintiff KLAUDIA WILCZKOWIAK is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 868.) - 154 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 155 of 414 PagelD #: 921 850. Plaintiff JAMES WRAY is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 869.) 851. Plaintiff LEROY ANDERSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 870.) 852. Plaintiff ALEXANDER ARRORACI is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 871.) 853. Plaintiff RENEE BAYLIS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 872.) 854. Plaintiff DENNIS BULMER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 873.) 855. Plaintiff RICHARD CARROLL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 874.) 856. Plaintiff DORIS COBURN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 875.) - 155 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 156 of 414 PagelD #: 922 857. Plaintiff GEORGE COBURN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 876.) 858. Plaintiff KC CRANDALL is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 877.) 859. Plaintiff KEITH DENSON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 878.) 860. Plaintiff SALLY FIGUEIREDO is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 879.) 861. Plaintiff CHERYL FORD is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 880.) 862. Plaintiff EDGART GONZALEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 881.) 863. Plaintiff STEVE KONG is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 882.) - 156 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 157 of 414 PagelD #: 923 864. Plaintiff JEFF LAVENDER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 883.) 865. Plaintiff MARA LAVENDER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 884.) 866. Plaintiff ROBERT LEWIN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 885.) 867. Plaintiff JAMES LOCKER is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 886.) 868. Plaintiff AVELINO MARTINEZ is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 887.) 869. Plaintiff AIDA MEZA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 888.) 870. Plaintiff JOSE MEZA is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 889.) - 157 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 158 of 414 PagelD #: 924 87 1 . Plaintiff VIRGEN MONDRAGON is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 890.) 872. Plaintiff WILLIAM OAKS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 891.) 873. Plaintiff DOMINADOR RAMOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 892.) 874. Plaintiff PETRONILLA RAMOS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 893.) 875. Plaintiff ESME ROSS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 884.) 876. Plaintiff ROBERT ROSS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 895.) 877. Plaintiff CHRISTINE SHIPMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 896.) - 158 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 159 of 414 PagelD #: 925 878. Plaintiff JAMES SHJPMAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 897.) 879. Plaintiff CHARLES TAM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 898.) 880. Plaintiff RUBY TAM is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 899.) 881. Plaintiff RAYMOND TRAN is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 900.) 882. Plaintiff ROBERTO VARGAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 901.) 883. Plaintiff RUTH VARGAS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 902.) 884. Plaintiff RONALD WILLIAMS is a resident of the State of California and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 903.) - 159 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 160 of 414 PagelD #: 926 885. Plaintiff NASIR FAIZI is a resident of the State of New York, County of Kings, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 904.) 886. Plaintiff JULIE KESTENBAUM is a resident of the State of Florida, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 905.) 887. Plaintiff PAUL KESTENBAUM is a resident of the City and State of Philadelphia, Pennsylvania, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 906.) 888. Plaintiffs SPENCER GARNER is a resident of the State of Colorado, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 907.) 889. Plaintiff DANIEL FREEMAN is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 908.) 890. Plaintiff LARRY CONTIER is a resident of the State of Colorado, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 909.) 891. Plaintiff KAREN CONTIER is a resident of the State of Colorado, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 910.) - 160 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 161 of 414 PagelD #: 927 892. Plaintiff CLARISSE PICHE is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 911.) 893 . Plaintiff MAURICIO B ARRAGAN is a resident of the State of Nevada, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 912.) 894. Plaintiff RAFAEL RIVIRA is a resident of the State of Georgia, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 913.) 895. Plaintiff PATRICIA SMITHSON is a resident of the State of Washington, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 914.) 896. Plaintiff LYNDEN SMITHSON is a resident of the State of Washington, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 915.) 897. Plaintiff JOYCE GALVEZ is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 916.) 898. Plaintiff DEJAN JUROKOV is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 917.) - 161 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 162 of 414 PagelD #: 928 899. Plaintiff HEWLETT DAN QUILLEN is a resident of the State of Alabama, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 918.) 900. Plaintiff TROY DANELLA is a resident of the State of North Carolina, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 919.) 901 . Plaintiff LORRAINE DANELLA is a resident of the State of North Carolina, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 920.) 902. Plaintiff ROGER STEWART is a resident of the State of Washington, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 921.) 903. Plaintiff NANCY MAE MARESH is a resident of the State of Colorado, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 922.) 904. Plaintiff JUDITH ANNE BLAIR is a resident of the State of Colorado, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 923.) 905. Plaintiff ALICE TOMASELLO is a resident of the State of Texas, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 924.) - 162 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 163 of 414 PagelD #: 929 906. Plaintiff CONNIE PATTERSON is a resident of the State of Texas, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 925.) 907. Plaintiff TERI SKRDLA is a resident of the State of South Dakota, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 926.) 908. Plaintiff MIKE SKRDLA is a resident of the State of South Dakota, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 927.) 909. Plaintiff JOHN KRUMSIEK is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 928.) 910. Plaintiff ANDREW P. BUCKLEY is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 929.) 911. Plaintiff BONNIE BUCKLEY is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 930.) 912. Plaintiff STEVE PASION is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 931.) - 163 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 164 of 414 PagelD #: 930 913. Plaintiff JANICE PASION is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 932.) 914. Plaintiff BELINDA KRUMSIEK is a resident of the State of California, and had a mortgage loan that was originated or serviced by one of the Defendants herein. (This Plaintiff shall be designated as Plaintiff No. 933.) 915. Each Plaintiff herein had ownership and possession of funds — material to the allegations herein — in a sum of between $25,000.00 and $65,000.00 and in no event no more than $75,000.00, as of January 22, 2003. 916. Each Plaintiff worked hard for these funds and earned them, paid state and federal taxes on them, and had the exclusive dominion and control over them. B. The Defendants 917. Through the wrongful conduct set forth in this complaint, the Defendants - and each of them - converted all of said funds and have continued the hiding and secreting of these funds from the period beginning on or about January 22, 2003 and continuing at all times thereafter. 918. At all times, the Defendants - and each of them, as they entered the conspiracy alleged herein - continued to hide and secrete the converted funds despite demands that they cease and desist from doing so by the Plaintiffs. 919. Plaintiffs neither consented to nor ratified the Defendants' conversion of their money as set forth in this complaint. - 164 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 165 of 414 PagelD #: 931 920. Defendant BANK OF AMERICA, NA. is a national banking association with its principal place of business located in Delaware ("BofA"). (This Defendant shall be designated as Defendant No. la.) 921. Defendant BANK OF AMERICA CORPORATION is a Delaware corporation ("BofAC"). (This Defendant shall be designated as Defendant No. lb.) 922. Defendant ERIC HOLDER is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 2.) 923. Defendant ANTHONY WEST is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 3.) 924. Defendant UNITED STATES OF AMERICA is an involuntary plaintiff. (This Defendant shall be designated as Defendant No. 4.) 925. Defendant THE STATE OF NEW YORK is an involuntary plaintiff. (This Defendant shall be designated as Defendant No. 5.) 926. Defendant JON CORZINE is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 1.) 927. Defendant VALERIE JARRETT is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 6. 928. Defendant KAMALA HARRIS is a resident of the State of California (This Defendant shall be designated as Defendant No. 7.) 929. Defendant MYA HARRIS-WEST is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 8.) 930. Defendant ANNITA DUN is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 9.) - 165 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 166 of 414 PagelD #: 932 931. Defendant ROBERT BAUER is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 10.) 932. Defendant JEREMY BEN-AMI is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 11.) 933. Defendant J STREET, INC., an entity form unknown, has its principal place of business in Washington, D.C. (This Defendant shall be designated as Defendant No. 12.) 934. Defendant HOWARD DICKSTEIN is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 13.) 935. Defendant JENNINE ENGLISH is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 14.) 936. Defendant THOMAS V. GIRARDI is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 15.) 937. Defendant WALTER LACK is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 16.) 938. Defendant ERIC GEORGE is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the - 166 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 167 of 414 PagelD #: 933 epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 17.) 939. Defendant SANDOR SAMUELS is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 18.) 940. Defendant ALAN ROTHENBERG is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 19.) 941. Defendant THOMAS LAYTON is a resident of the State of California. (This Defendant shall be designated as Defendant No. 20.) 942. Defendant JOHN HOONEN is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 21.) 943. Defendant DAVID BROCK is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 22.) - 167 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 168 of 414 PagelD #: 934 944. Defendant PETER KRAUSE is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 23.) 945. Defendant MARY ROBERTS is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 24.) 946. Defendant MEDIA MATTERS is a corporation form unknown. (This Defendant shall be designated as Defendant No. 25.) 947. Defendant DANIELLE LEE is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 26.) 948. Defendant JOSEPH DUNN is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 27.) 949. Defendant JERRY FALK is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 28.) - 168 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 169 of 414 PagelD #: 935 950. Defendant DOUGLAS WINTHROP is is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 1.) 951. Defendant KENNETH LEWIS is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 29.) 952. Defendant TODD TORR is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 30.) 953. Defendant JEFFREY HUVELLE is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 31.) 954. Defendant JOSEPH CRUDO, SR. is a resident of the State of California. (This Defendant shall be designated as Defendant No. 32.) 955. Defendant JOSEPH CRUDO, JR. is a resident of the State of California. (This Defendant shall be designated as Defendant No. 33.) - 169 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 170 of 414 PagelD #: 936 956. Defendant MICHAEL BROSNAN is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 34.) 957. Defendant WILLIAM WARDLAW is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 35.) 958. Defendant ALAN I. ROTHENBERG is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 36.) 959. Defendant DAVID J. PASTERNAK is a resident of the State of California (This Defendant shall be designated as Defendant No. 37.) 960. Defendant HOWARD MILLER is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 38.) 961. Defendant SCOTT DREXEL is a defendant who maintains residences across the United States, is an active member of the conspiracy set forth herein - 170 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 171 of 414 PagelD #: 937 the epicenter of which is Manhattan, and is subject to jurisdiction in New York as a consequence. (This Defendant shall be designated as Defendant No. 39.) 962. Defendant 1 st CENTURY BANK aka FIRST CENTURY BANK is an entity form unknown. (This Defendant shall be designated as Defendant No. 40.) 963. Defendant FIRST CENTURY BANKSHARES, INC. is a Delaware corporation. (This Defendant shall be designated as Defendant No. 41.) 964. Defendant COUNTRYWIDE FINANCIAL CORPORATION, dba BAC HOME LOANS SERVICING is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 42.) 965. Defendant COUNTRYWIDE HOME LOANS, INC. is a resident of the State of New York. (This Defendant shall be designated as Defendant No. 43.) 966. Defendant COUNTRYWIDE FINANCIAL CORPORATION is a Delaware corporation doing business as BAC HOME LOANS SERVICING ("CWFC"). (This Defendant shall be designated as Defendant No. 45.) 967. Defendant COUNTRYWIDE HOME LOANS, INC. is a New York corporation ("CWHL"). (This Defendant shall be designated as Defendant No. 46.) 968. Defendant JPMorgan Chase Bank, N.A. is a national bank with its principal place of business located in New York, New York ("Chase Bank"). Chase Bank purchased the assets and assumed the liabilities of Washington Mutual Bank, F.S.B. after it failed in 2008 ("WAMU"). (This Defendant shall be designated as Defendant No. 47.) - 171 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 172 of 414 PagelD #: 938 969. Defendant Chase Home Finance, LLC is a Delaware limited liability company and is a subsidiary of Chase Bank ("Chase Finance"). (This Defendant shall be designated as Defendant No. 48.) 970. Defendant WELLS FARGO & COMPANY, a Delaware corporation with its principal place of business in California, is, among other things, a mortgage lender doing business in the State of California, County of Los Angeles, as well as across the country ("Wells Fargo Co"). (This Defendant shall be designated as Defendant No. 49.) 971. Defendant WELLS FARGO BANK, N. A., is a bank subsidiary of Wells Fargo Company and is a business entity operating in the State of California ("Wells Fargo"). (This Defendant shall be designated as Defendant No. 50.) 972. Defendant WACHOVIA BANK is a division of Wells Fargo Bank, N. A., a bank subsidiary of Wells Fargo & Company, and is a business entity operating in the State of California ("Wachovia"). (This Defendant shall be designated as Defendant No. 51.) 973. CFTIGROUP, INC. is a banking corporation with its principal place of business located in New York, County of Kings ("Citigroup"). (This Defendant shall be designated as Defendant No. 52.) 974. CITIBANK NA. is a national banking association with its principal place of business located in New York ("Citibank"). (This Defendant shall be designated as Defendant No. 53.) - 172 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 173 of 414 PagelD #: 939 975. U.S. BANCORP is a banking corporation with its principal place of business located in Delaware ("US Bancorp"). (This Defendant shall be designated as Defendant No. 54.) 976. U.S. BANK, NA. is a national banking association with its principal place of business located in Minnesota ("US BANK"). (This Defendant shall be designated as Defendant No. 55.) 977. U.S. BANK TRUST COMPANY N.A. is a national banking association with its principal place of business located in Oregon ("USBTC"). (This Defendant shall be designated as Defendant No. 56.) 978. U.S. BANK TRUST N.A. is a national banking association with its principal place of business located in Delaware ("USBT"). (This Defendant shall be designated as Defendant No. 57.) 979. Defendant ALLY BANK, NA is a resident of the State of New York with its principal place of business located in New York. (This Defendant shall be designated as Defendant No. 58.) 980. ALLY FINANCIAL, INC. is a banking corporation with its principal place of business located in Michigan ("Ally"). (This Defendant shall be designated as Defendant No. 59.) 981. GENERAL MOTORS ACCEPTANCE CORPORATION is a banking corporation with its principal place of business located in Michigan ("GMAC"). (This Defendant shall be designated as Defendant No. 60.) - 173 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 174 of 414 PagelD #: 940 982. ONEWEST BANK, F.S.B. is a federal savings bank with its principal place of business located in California ("Onewest"). (This Defendant shall be designated as Defendant No. 61.) 983. HSBC HOLDINGS, PLC is an unknown business entity with its principal place of business located in the United Kingdom ("HSBC"). (This Defendant shall be designated as Defendant No. 62.) 984. AURORA BANK, F.S.B. is a federal savings bank with its principal place of business located in Delaware ("Aurora"). (This Defendant shall be designated as Defendant No. 63.) 985. OCWEN FINANCIAL CORPORATION is a banking corporation with its principal place of business located in Georgia ("Ocwen"). (This Defendant shall be designated as Defendant No. 64.) 986. DEUTSCHE BANK AG is an unknown business entity with its principal place of business located in Germany ("Deutsche AG"). (This Defendant shall be designated as Defendant No. 65.) 987. DEUTSCHE BANK NATIONAL TRUST COMPANY is an unknown business entity with its principal place of business located in California ("Deutsche Bank"). (This Defendant shall be designated as Defendant No. 66.) 988. EMC MORTGAGE CORPORATION is a Delaware corporation with its principal place of business located in Texas ("EMC Mortgage"). EMC is an affiliate of Chase Bank. (This Defendant shall be designated as Defendant No. 67.) - 174 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 175 of 414 PagelD #: 941 989. PNC BANK, N.A. is a national banking association with its principal place of business located in Pennsylvania ("PNC"). (This Defendant shall be designated as Defendant No. 68.) 990. ING GROUP is an unknown business entity with its principal place of business located in the Netherlands ("PNG"). (This Defendant shall be designated as Defendant No. 69.) 991. BofA, BofAC, CWFC, CWHL, Chase Bank, WAMU, Chase Finance, Wells Fargo Co, Wells Fargo, Wachovia, Citigroup, Citibank, US Bancorp, US Bank, USBTC, USBT, Ally, GMAC, Onewest, HSBC, Aurora, Ocwen, Deutsche AG, Deutsche Bank, EMC, EMC Mortgage, PNC, ING, along with their affiliated entities during or before the time that they were affiliated, are referred to collectively herein as "Defendant Servicers." 992. Defendant Servicers, either directly or through their agents, employees, and subsidiaries, have serviced tens of thousands of residential real estate loans in the State of New York. Defendant Services have also filed thousands of foreclosure- related proceedings in the State of New York, including foreclosure actions filed in New York state courts and proofs of claims and applications to lift stays in the federal bankruptcy courts in the State of New York (collectively, "Foreclosure Proceedings"). 993. Defendant COUNTRYWIDE ALTERNATIVE INVESTMENTS is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 70.) - 175 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 176 of 414 PagelD #: 942 994. Defendant COUNTRYWIDE CAPITAL I is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 71.) 995. Defendant COUNTRYWIDE CAPITAL II is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 72.) 996. Defendant COUNTRYWIDE CAPITAL III is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 73.) 997. Defendant COUNTYWIDE CAPITAL IV is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 74.) 998. Defendant COUNTRYWIDE CAPITAL V is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 75.) 999. Defendant COUNTRYWIDE CAPITAL VI is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 76.) 1000. Defendant COUNTRYWIDE CAPITAL VII is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 77.) - 176 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 177 of 414 PagelD #: 943 1001. Defendant COUNTRYWIDE CAPITAL VIII is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 78.) 1002. Defendant COUNTRYWIDE CAPITAL IX is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 79.) 1003. Defendant COUNTRYWIDE CAPITAL MARKETS ASIA (HK) LIMITED is an Unknown Business Entity located in China. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 80.) 1004. Defendant COUNTYWIDE CAPITAL MARKETS, LLC is a Limited Liability Company located in California. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 81.) 1005. Defendant COUNTRYWIDE COMMERCIAL JPI LLC is a Limited Liability Company located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 82.) 1006. Defendant COUNTRYWIDE COMMERCIAL MORTGAGE CAPITAL, INC. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 83.) - 177 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 178 of 414 PagelD #: 944 1007. Defendant COUNTRYWIDE COMMERCIAL REAL ESTATE FINANCE is a Corporation located in California. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 84.) 1008. Defendant COUNTRYWIDE HILLCREST I is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 85.) 1009. Defendant COUNTRYWIDE INTERNATIONAL GP HOLDINGS is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 86.) 1010. Defendant COUNTRYWIDE MANAGEMENT CORPORATION is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 87.) 1011. Defendant COUNTRYWIDE MORTGAGE VENTURES, LLC is a Limited Liability Company located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 88.) 1012. Defendant COUNTRYWIDE INTERNATIONAL TECHNOLOGY HOLDINGS LIMITED is an Unknown Business Entity located in Island of Guernsey. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 89.) - 178 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 179 of 414 PagelD #: 945 1013. Defendant COUNTRYWIDE WAREHOUSE LENDING is an Unknown Business Entity located in California. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 90.) 1014. Defendant CWABS II, INC. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 91.) 1015. Defendant CWALT, INC. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 92.) 1016. Defendant CYRUS ACCESS, LTD. is an Unknown Business Entity located in New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 93.) 1017. Defendant DIVERSIFIED ALPHA FUND (MASTER), LTD. is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 94.) 1018. Defendant HALCYON ACCESS, LTD. is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 95.) 1019. Defendant INDOPARK HOLDINGS, LTD. is an Unknown Business Entity located in Mauritius. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 96.) - 179 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 180 of 414 PagelD #: 946 1020. Defendant INVESTMENTS 2234 PHILIPPINES FUND I (SPV-AMC), INC. is a Corporation located in Philippines. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 97.) 1021. Defendant ML BANDERIA CAYMAN BRL INC. is a Corporation located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 98.) 1022. Defendant ML WHITBY LUXEMBOURG S.A.R.L. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 99.) 1023. Defendant ZEUS RECOVERY FUND, S.A. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 100. ) 1024. Defendant J.P. MORGAN MANSART INVESTMENTS is an Unknown Business Entity located in France. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 101. ) 1025. Defendant SAPOTORO COOPERATIEF U.A. is an Unknown Business Entity located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 102. ) - 180 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 181 of 414 PagelD #: 947 1026. Defendant ONE EQUITY PARTNERS II, L.P. is a Limited Partnership located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 103.) 1027. Defendant ONE EQUITY PARTNERS III, L.P. is a Limited Partnership located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 104. ) 1028. Defendant ONE EQUITY PARTNERS IV, L.P. is a Limited Partnership located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 105. ) 1029. Defendant ONE EQUITY PARTNERS LLC is a Limited Liability Company located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 106.) 1030. Defendant BEAR STEARNS INTERNATIONAL FUNDING I S.A.R.L. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 107.) 1031. Defendant J.P. MORGAN DUBLIN FINANCIAL HOLDINGS LIMITED is an Unknown Business Entity located in Ireland. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 108.) - 181 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 182 of 414 PagelD #: 948 1032. Defendant J.P. MORGAN FINANCE JAPAN YK is an Unknown Business Entity located in Japan. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 109.) 1033. Defendant J.P. MORGAN SERVICES INDIA PRIVATE LIMITED is an Unknown Business Entity located in India. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 110.) 1034. Defendant HENRY BATH BV is a Private Limited Liability Company located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 111.) 1035. Defendant GAVEA INVESTEVIENTOS LTDA. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 112.) 1036. Defendant J.P. MORGAN RESEARCH TOTAL RETURN MASTER FUND LTD. is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 113.) 1037. Defendant J.P. MORGAN DISTRESSED DEBT MASTER FUND LTD. is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 114.) 1038. Defendant J.P. MORGAN GREATER CHINA PORPERTY FUND CAYMAN SLP L.P. is a Limited Partnership located in Cayman Islands. This Defendant is fully - 182 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 183 of 414 PagelD #: 949 subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1 15.) 1039. Defendant J.P. MORGAN ASSET MANAGEMENT HOLDINGS (LUXEMBOURG) S.A.R.L. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 116.) 1040. Defendant J.P. MORGAN ASSET MANAGEMENT HOLDINGS LUXEMBOURG S.A. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 117.) 1041. Defendant J.P. MORGAN CHASE CUSTODY SERVICES, INC. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 118.) 1042. Defendant ATACAMA MULTIMERCADO - FUNDO DE INVESTIMENTO is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1 19.) 1043. Defendant J.P. MORGAN S.A. DISTRIBUIDORA DE TITULOS E VALORES MOBILIARIOS is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 120.) - 183 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 184 of 414 PagelD #: 950 1044. Defendant J.P. MORGAN BANK LUXEMBOURG S.A. is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 121.) 1045. Defendant BANCO J.P. MORGAN S.A., INSTITUCION DE BANCA MULTIPLE, J.P. MORGAN GRUPO FINANCIERO is an Unknown Business Entity located in Mexico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 122.) 1046. Defendant J.P. MORGAN INTERNATIONAL HOLDINGS LIMITED is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 123.) 1047. Defendant J.P. MORGAN CHASE BANK (CHINA) COMPANY LIMITED is an Unknown Business Entity located in People's Republic of China. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 124.) 1048. Defendant J.P. MORGAN PCA HOLDINGS (MAURITIUS) I LIMITED is an Unknown Business Entity located in Mauritius. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 125.) - 184 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 185 of 414 PagelD #: 951 1049. Defendant DANUBE HOLDINGS I C.V. is a Limited Partnership located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 126.) 1050. Defendant DANUBE HOLDINGS III C.V. is a Limited Partnership located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 127.) 1051. Defendant EUROPEAN CREDIT FUND SICAV II is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 128.) 1052. Defendant EVERGREEN ECM HOLDINGS B.V. is a Limited Liability Company located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 129.) 1053. Defendant GOLDEN FUNDING COMPANY is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 130.) 1054. Defendant ISLAND FINANCE HOLDING COMPANY, LLC is a Limited Liability Company located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 131.) - 185 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 186 of 414 PagelD #: 952 1055. Defendant JORDAN INVESTMENTS LP UK is a Limited Partnership located in UK - Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 132.) 1056. Defendant NORWEST VENTURE PARTNERS FVCI SINGAPORE PRIVATE LIMITED is an Unknown Business Entity located in Singapore. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 133.) 1057. Defendant NORWEST VENTURE PARTNERS VI, LP is a Limited Partnership located in Minnesota. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 134.) 1058. Defendant NORWEST VENTURE PARTNERS VI- A, LP is a Limited Partnership located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 135.) 1059. Defendant NORWEST VENTURE PARTNERS VII, LP is a Limited Partnership located in Minnesota. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 136.) 1060. Defendant NORWEST VENTURE PARTNERS VII- A FII MAURITIUS is an Unknown Business Entity located in Mauritius. This Defendant is fully subject to - 186 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 187 of 414 PagelD #: 953 jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 137.) 1061. Defendant NORWEST VENTURE PARTNERS VII-A FVCI MAURITIUS is an Unknown Business Entity located in Mauritius. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 138.) 1062. Defendant NORWEST VENTURE PARTNERS VII-A MAURITIUS is an Unknown Business Entity located in Mauritius. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 139.) 1063. Defendant OVERLAND RELATIVE VALUE FUND LTD. is an Unknown Business Entity located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 140.) 1064. Defendant OVERLAND RELATIVE VALUE MASTER FUND LP is a Limited Partnership located in Cayman Islands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 141.) 1065. Defendant PARTNERSHIP INVESTMENTS S.A.R.L. is a Private Limited Company located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 142.) - 187 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 188 of 414 PagelD #: 954 1066. Defendant CITIGROUP, N.A., is an Unknown Business Entity located with its principal place of business in New York, New York. This Defendant is fully subject to jurisdiction this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 143.) 1067. Defendant CITIBANK (CHINA) CO., LTD. is an Unknown Business Entity located in China. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 144.) 1068. Defendant CITIBANK DEL PERU SA. is a Corporation located in Peru. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 145) 1069. Defendant CITIBANK MAGHREB is an Unknown Business Entity located in Morocco. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 146.) 1070. Defendant BANCO CITIBANK DE GUETEMALA, SA. is a Corporation located in Guetemala. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 147.) 1071. Defendant BANCO CITIBANK SA. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 148.) 1072. Defendant CHELSEA PARTICIPACOES SOCIETARIAS E INVESTIMENTOS LTDA. is an Unknown Business Entity located in Brazil. This Defendant is fully - 188 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 189 of 414 PagelD #: 955 subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 149.) 1073. Defendant CITIBANK - DISTRIBUIDORA DE TITULOS E VALORES MOBILIARIOS S.A. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 150.) 1074. Defendant ALTERNATIVE LOAN TRUST 2004- 10CB shall be designated as Defendant No. 151. 1075. Defendant ALTERNATIVE LOAN TRUST 2004-12CB shall be designated as Defendant No. 152. 1076. Defendant ALTERNATIVE LOAN TRUST 2004-13CB shall be designated as Defendant No. 153. 1077. Defendant ALTERNATIVE LOAN TRUST 2004- 14T2 shall be designated as Defendant No. 154. 1078. Defendant ALTERNATIVE LOAN TRUST 2004-15 shall be designated as Defendant No. 155. 1079. Defendant ALTERNATIVE LOAN TRUST 2004-16CB shall be designated as Defendant No. 156. 1080. Defendant ALTERNATIVE LOAN TRUST 2004-17CB shall be designated as Defendant No. 157. 1081. Defendant ALTERNATIVE LOAN TRUST 2004- 18CB shall be designated as Defendant No. 158. - 189 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 190 of 414 PagelD #: 956 1082. Defendant ALTERNATIVE LOAN TRUST 2004-20T1 shall be designated as Defendant No. 159. 1083. Defendant ALTERNATIVE LOAN TRUST 2004-22CB shall be designated as Defendant No. 160. 1084. Defendant ALTERNATIVE LOAN TRUST 2004-24CB shall be designated as Defendant No. 161. 1085. Defendant ALTERNATIVE LOAN TRUST 2004-25CB shall be designated as Defendant No. 162. 1086. Defendant ALTERNATIVE LOAN TRUST 2004-26T1 shall be designated as Defendant No. 163. 1087. Defendant ALTERNATIVE LOAN TRUST 2004-27CB shall be designated as Defendant No. 164. 1088. Defendant ALTERNATIVE LOAN TRUST 2004-7T1 shall be designated as Defendant No. 165. 1089. Defendant ALTERNATIVE LOAN TRUST 2004-8CB shall be designated as Defendant No. 166. 1090. Defendant ALTERNATIVE LOAN TRUST 2004-9T1 shall be designated as Defendant No. 167. 1091. Defendant ALTERNATIVE LOAN TRUST 2004- J7 shall be designated as Defendant No. 168. 1092. Defendant ALTERNATIVE LOAN TRUST 2004-J8 shall be designated as Defendant No. 169. - 190 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 191 of 414 PagelD #: 957 1093. Defendant ALTERNATIVE LOAN TRUST 2004-J9 shall be designated as Defendant No. 170. 1094. Defendant ALTERNATIVE LOAN TRUST 2005-10CB shall be designated as Defendant No. 171. 1095. Defendant ALTERNATIVE LOAN TRUST 2005-1 1CB shall be designated as Defendant No. 172. 1096. Defendant ALTERNATIVE LOAN TRUST 2005-13CB shall be designated as Defendant No. 173. 1097. Defendant ALTERNATIVE LOAN TRUST 2005-14 shall be designated as Defendant No. 174. 1098. Defendant ALTERNATIVE LOAN TRUST 2005-16 shall be designated as Defendant No. 175. 1099. Defendant ALTERNATIVE LOAN TRUST 2005-17 shall be designated as Defendant No. 176. 1100. Defendant ALTERNATIVE LOAN TRUST 2005-18CB shall be designated as Defendant No. 177. 1101. Defendant ALTERNATIVE LOAN TRUST 2005-19CB shall be designated as Defendant No. 178. 1102. Defendant ALTERNATIVE LOAN TRUST 2005-20CB shall be designated as Defendant No. 179. 1103. Defendant ALTERNATIVE LOAN TRUST 2005-21CB shall be designated as Defendant No. 180. - 191 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 192 of 414 PagelD #: 958 1104. Defendant ALTERNATIVE LOAN TRUST 2005-22T1 shall be designated as Defendant No. 181. 1105. Defendant ALTERNATIVE LOAN TRUST 2005-23CB shall be designated as Defendant No. 182. 1106. Defendant ALTERNATIVE LOAN TRUST 2005-24 shall be designated as Defendant No. 183. 1107. Defendant ALTERNATIVE LOAN TRUST 2005-25T1 shall be designated as Defendant No. 184. 1108. Defendant ALTERNATIVE LOAN TRUST 2005-26CB shall be designated as Defendant No. 185. 1109. Defendant ALTERNATIVE LOAN TRUST 2005-27 shall be designated as Defendant No. 186. 1110. Defendant ALTERNATIVE LOAN TRUST 2005-28CB shall be designated as Defendant No. 187. 1111. Defendant ALTERNATIVE LOAN TRUST 2005-29CB shall be designated as Defendant No. 188. 1112. Defendant ALTERNATIVE LOAN TRUST 2005-30CB shall be designated as Defendant No. 189. 1113. Defendant ALTERNATIVE LOAN TRUST 2005-31 shall be designated as Defendant No. 190. 1114. Defendant ALTERNATIVE LOAN TRUST 2005-32T1 shall be designated as Defendant No. 191. - 192 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 193 of 414 PagelD #: 959 1115. Defendant ALTERNATIVE LOAN TRUST 2005-33CB shall be designated as Defendant No. 192. 1116. Defendant ALTERNATIVE LOAN TRUST 2005-34CB shall be designated as Defendant No. 193. 1117. Defendant ALTERNATIVE LOAN TRUST 2005-35CB shall be designated as Defendant No. 194. 1118. Defendant ALTERNATIVE LOAN TRUST 2005-36 shall be designated as Defendant No. 195. 1119. Defendant ALTERNATIVE LOAN TRUST 2005-37T1 shall be designated as Defendant No. 196. 1120. Defendant ALTERNATIVE LOAN TRUST 2005-38 shall be designated as Defendant No. 197. 1121. Defendant ALTERNATIVE LOAN TRUST 2005-4 shall be designated as Defendant No. 198. 1122. Defendant ALTERNATIVE LOAN TRUST 2005-40CB shall be designated as Defendant No. 199. 1123. Defendant ALTERNATIVE LOAN TRUST 2005-41 shall be designated as Defendant No. 200. 1124. Defendant ALTERNATIVE LOAN TRUST 2005-42CB shall be designated as Defendant No. 201. 1125. Defendant ALTERNATIVE LOAN TRUST 2005-43 shall be designated as Defendant No. 202. - 193 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 194 of 414 PagelD #: 960 1126. Defendant ALTERNATIVE LOAN TRUST 2005-44 shall be designated as Defendant No. 203. 1127. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 204. 1128. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 205. 1129. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 206. 1130. Defendant ALTERNATIVE LOAN TRUST 2005-46CB shall be designated as Defendant No. 207. 1131. Defendant ALTERNATIVE LOAN TRUST 2005-47CB shall be designated as Defendant No. 208. 1132. Defendant ALTERNATIVE LOAN TRUST 2005-48T1 shall be designated as Defendant No. 209. 1133. Defendant ALTERNATIVE LOAN TRUST 2005-49CB shall be designated as Defendant No. 210. 1134. Defendant ALTERNATIVE LOAN TRUST 2005-50CB shall be designated as Defendant No. 211. 1135. Defendant ALTERNATIVE LOAN TRUST 2005-51 shall be designated as Defendant No. 212. 1136. Defendant ALTERNATIVE LOAN TRUST 2005-53T2 shall be designated as Defendant No. 213. - 194 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 195 of 414 PagelD #: 961 1137. Defendant ALTERNATIVE LOAN TRUST 2005-54CB shall be designated as Defendant No. 214. 1138. Defendant ALTERNATIVE LOAN TRUST 2005-55CB shall be designated as Defendant No. 215. 1139. Defendant ALTERNATIVE LOAN TRUST 2005-56 shall be designated as Defendant No. 216. 1140. Defendant ALTERNATIVE LOAN TRUST 2005-56 shall be designated as Defendant No. 217. 1141. Defendant ALTERNATIVE LOAN TRUST 2005-57CB shall be designated as Defendant No. 218. 1142. Defendant ALTERNATIVE LOAN TRUST 2005-58 shall be designated as Defendant No. 219. 1143. Defendant ALTERNATIVE LOAN TRUST 2005-59 shall be designated as Defendant No. 220. 1144. Defendant ALTERNATIVE LOAN TRUST 2005-60T1 shall be designated as Defendant No. 221. 1145. Defendant ALTERNATIVE LOAN TRUST 2005-61 shall be designated as Defendant No. 222. 1146. Defendant ALTERNATIVE LOAN TRUST 2005-62 shall be designated as Defendant No. 223. 1147. Defendant ALTERNATIVE LOAN TRUST 2005-63 shall be designated as Defendant No. 224. - 195 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 196 of 414 PagelD #: 962 1148. Defendant ALTERNATIVE LOAN TRUST 2005-64CB shall be designated as Defendant No. 225. 1149. Defendant ALTERNATIVE LOAN TRUST 2005-65CB shall be designated as Defendant No. 226. 1150. Defendant ALTERNATIVE LOAN TRUST 2005-6CB shall be designated as Defendant No. 227. 1151. Defendant ALTERNATIVE LOAN TRUST 2005-70CB shall be designated as Defendant No. 228. 1152. Defendant ALTERNATIVE LOAN TRUST 2005-71 shall be designated as Defendant No. 229. 1153. Defendant ALTERNATIVE LOAN TRUST 2005-74T1 shall be designated as Defendant No. 230. 1154. Defendant ALTERNATIVE LOAN TRUST 2005-75CB shall be designated as Defendant No. 231. 1155. Defendant ALTERNATIVE LOAN TRUST 2005-75CB shall be designated as Defendant No. 232. 1156. Defendant ALTERNATIVE LOAN TRUST 2005-76 shall be designated as Defendant No. 233. 1157. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 234. 1158. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 235. - 196 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 197 of 414 PagelD #: 963 1159. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 236. 1160. Defendant ALTERNATIVE LOAN TRUST 2005-79CB shall be designated as Defendant No. 237. 1161. Defendant ALTERNATIVE LOAN TRUST 2005-7CB shall be designated as Defendant No. 238. 1162. Defendant ALTERNATIVE LOAN TRUST 2005-80CB shall be designated as Defendant No. 239. 1163. Defendant ALTERNATIVE LOAN TRUST 2005-81 shall be designated as Defendant No. 240. 1164. Defendant ALTERNATIVE LOAN TRUST 2005-82 shall be designated as Defendant No. 241. 1165. Defendant ALTERNATIVE LOAN TRUST 2005-82 shall be designated as Defendant No. 242. 1166. Defendant ALTERNATIVE LOAN TRUST 2005-83CB shall be designated as Defendant No. 243. 1167. Defendant ALTERNATIVE LOAN TRUST 2005-84 shall be designated as Defendant No. 244. 1168. Defendant ALTERNATIVE LOAN TRUST 2005-85CB shall be designated as Defendant No. 245. 1169. Defendant ALTERNATIVE LOAN TRUST 2005-86CB shall be designated as Defendant No. 246. - 197 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 198 of 414 PagelD #: 964 1170. Defendant ALTERNATIVE LOAN TRUST 2005-9CB shall be designated as Defendant No. 247. 1171. Defendant ALTERNATIVE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 248. 1172. Defendant ALTERNATIVE LOAN TRUST 2005-IM1 shall be designated as Defendant No. 249. 1173. Defendant ALTERNATIVE LOAN TRUST 2005-J10 shall be designated as Defendant No. 250. 1174. Defendant ALTERNATIVE LOAN TRUST 2005-J11 shall be designated as Defendant No. 251. 1175. Defendant ALTERNATIVE LOAN TRUST 2005-J11 shall be designated as Defendant No. 252. 1176. Defendant ALTERNATIVE LOAN TRUST 2005-J4 shall be designated as Defendant No. 253. 1177. Defendant ALTERNATIVE LOAN TRUST 2005-J6 shall be designated as Defendant No. 254. 1178. Defendant ALTERNATIVE LOAN TRUST 2005-J7 shall be designated as Defendant No. 255. 1179. Defendant ALTERNATIVE LOAN TRUST 2006-0C5 shall be designated as Defendant No. 256. 1180. Defendant ALTERNATIVE LOAN TRUST 2006-1 1CB shall be designated as Defendant No. 257. - 198 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 199 of 414 PagelD #: 965 1181. Defendant ALTERNATIVE LOAN TRUST 2006- 12CB shall be designated as Defendant No. 258. 1182. Defendant ALTERNATIVE LOAN TRUST 2006-13T1 shall be designated as Defendant No. 259. 1183. Defendant ALTERNATIVE LOAN TRUST 2006-14CB shall be designated as Defendant No. 260. 1184. Defendant ALTERNATIVE LOAN TRUST 2006-15CB shall be designated as Defendant No. 261. 1185. Defendant ALTERNATIVE LOAN TRUST 2006-16CB shall be designated as Defendant No. 262. 1186. Defendant ALTERNATIVE LOAN TRUST 2006- 17T1 shall be designated as Defendant No. 263. 1187. Defendant ALTERNATIVE LOAN TRUST 2006- 18CB shall be designated as Defendant No. 264. 1188. Defendant ALTERNATIVE LOAN TRUST 2006-19CB shall be designated as Defendant No. 265. 1189. Defendant ALTERNATIVE LOAN TRUST 2006-20CB shall be designated as Defendant No. 266. 1190. Defendant ALTERNATIVE LOAN TRUST 2006-21CB shall be designated as Defendant No. 267. 1191. Defendant ALTERNATIVE LOAN TRUST 2006-2 1CB shall be designated as Defendant No. 268. - 199 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 200 of 414 PagelD #: 966 1192. Defendant ALTERNATIVE LOAN TRUST 2006-2 1CB shall be designated as Defendant No. 269. 1193. Defendant ALTERNATIVE LOAN TRUST 2006-23CB shall be designated as Defendant No. 270. 1194. Defendant ALTERNATIVE LOAN TRUST 2006-23CB shall be designated as Defendant No. 271. 1195. Defendant ALTERNATIVE LOAN TRUST 2006-24CB shall be designated as Defendant No. 272. 1196. Defendant ALTERNATIVE LOAN TRUST 2006-25CB shall be designated as Defendant No. 273. 1197. Defendant ALTERNATIVE LOAN TRUST 2006-25CB shall be designated as Defendant No. 274. 1198. Defendant ALTERNATIVE LOAN TRUST 2006-26CB shall be designated as Defendant No. 275. 1199. Defendant ALTERNATIVE LOAN TRUST 2006-26CB shall be designated as Defendant No. 276. 1200. Defendant ALTERNATIVE LOAN TRUST 2006-27CB shall be designated as Defendant No. 277. 1201. Defendant ALTERNATIVE LOAN TRUST 2006-28CB shall be designated as Defendant No. 278. 1202. Defendant ALTERNATIVE LOAN TRUST 2006-29T1 shall be designated as Defendant No. 279. - 200 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 201 of 414 PagelD #: 967 1203. Defendant ALTERNATIVE LOAN TRUST 2006-2CB shall be designated as Defendant No. 280. 1204. Defendant ALTERNATIVE LOAN TRUST 2006-30T1 shall be designated as Defendant No. 281. 1205. Defendant ALTERNATIVE LOAN TRUST 2006-3 1CB shall be designated as Defendant No. 282. 1206. Defendant ALTERNATIVE LOAN TRUST 2006-3 1CB shall be designated as Defendant No. 283. 1207. Defendant ALTERNATIVE LOAN TRUST 2006-32CB shall be designated as Defendant No. 284. 1208. Defendant ALTERNATIVE LOAN TRUST 2006-33CB shall be designated as Defendant No. 285. 1209. Defendant ALTERNATIVE LOAN TRUST 2006-34 shall be designated as Defendant No. 286. 1210. Defendant ALTERNATIVE LOAN TRUST 2006-35CB shall be designated as Defendant No. 287. 1211. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 288. 1212. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 289. 1213. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 290. - 201 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 202 of 414 PagelD #: 968 1214. Defendant ALTERNATIVE LOAN TRUST 2006-37R shall be designated as Defendant No. 291. 1215. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 292. 1216. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 293. 1217. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 294. 1218. Defendant ALTERNATIVE LOAN TRUST 2006-40T1 shall be designated as Defendant No. 295. 1219. Defendant ALTERNATIVE LOAN TRUST 2006-40T1 shall be designated as Defendant No. 296. 1220. Defendant ALTERNATIVE LOAN TRUST 2006-41CB shall be designated as Defendant No. 297. 1221. Defendant ALTERNATIVE LOAN TRUST 2006-42 shall be designated as Defendant No. 298. 1222. Defendant ALTERNATIVE LOAN TRUST 2006-43CB shall be designated as Defendant No. 299. 1223. Defendant ALTERNATIVE LOAN TRUST 2006-45T1 shall be designated as Defendant No. 300. 1224. Defendant ALTERNATIVE LOAN TRUST 2006-45T1 shall be designated as Defendant No. 301. - 202 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 203 of 414 PagelD #: 969 1225. Defendant ALTERNATIVE LOAN TRUST 2006-46 shall be designated as Defendant No. 302. 1226. Defendant ALTERNATIVE LOAN TRUST 2006-4CB shall be designated as Defendant No. 303. 1227. Defendant ALTERNATIVE LOAN TRUST 2006-5T2 shall be designated as Defendant No. 304. 1228. Defendant ALTERNATIVE LOAN TRUST 2006-6CB shall be designated as Defendant No. 305. 1229. Defendant ALTERNATIVE LOAN TRUST 2006-7CB shall be designated as Defendant No. 306. 1230. Defendant ALTERNATIVE LOAN TRUST 2006-7CB shall be designated as Defendant No. 307. 1231. Defendant ALTERNATIVE LOAN TRUST 2006-8T1 shall be designated as Defendant No. 308. 1232. Defendant ALTERNATIVE LOAN TRUST 2006-9T1 shall be designated as Defendant No. 309. 1233. Defendant ALTERNATIVE LOAN TRUST 2006-HY10 shall be designated as Defendant No. 310. 1234. Defendant ALTERNATIVE LOAN TRUST 2006-HY11 shall be designated as Defendant No. 311. 1235. Defendant ALTERNATIVE LOAN TRUST 2006-HY12 shall be designated as Defendant No. 312. - 203 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 204 of 414 PagelD #: 970 1236. Defendant ALTERNATIVE LOAN TRUST 2006-HY12 shall be designated as Defendant No. 313. 1237. Defendant ALTERNATIVE LOAN TRUST 2006-HY13 shall be designated as Defendant No. 314. 1238. Defendant ALTERNATIVE LOAN TRUST 2006-HY3 shall be designated as Defendant No. 315. 1239. Defendant ALTERNATIVE LOAN TRUST 2006-J1 shall be designated as Defendant No. 316. 1240. Defendant ALTERNATIVE LOAN TRUST 2006- J2 shall be designated as Defendant No. 317. 1241. Defendant ALTERNATIVE LOAN TRUST 2006- J2 shall be designated as Defendant No. 318. 1242. Defendant ALTERNATIVE LOAN TRUST 2006-J3 shall be designated as Defendant No. 319. 1243. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 320. 1244. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 321. 1245. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 322. 1246. Defendant ALTERNATIVE LOAN TRUST 2006-J5 shall be designated as Defendant No. 323. - 204 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 205 of 414 PagelD #: 971 1247. Defendant ALTERNATIVE LOAN TRUST 2006- J6 shall be designated as Defendant No. 324. 1248. Defendant ALTERNATIVE LOAN TRUST 2006-J7 shall be designated as Defendant No. 325. 1249. Defendant ALTERNATIVE LOAN TRUST 2006-J8 shall be designated as Defendant No. 326. 1250. Defendant ALTERNATIVE LOAN TRUST 2006-J8 shall be designated as Defendant No. 327. 1251. Defendant ALTERNATIVE LOAN TRUST 2006-OA1 shall be designated as Defendant No. 328. 1252. Defendant ALTERNATIVE LOAN TRUST 2006-OA10 shall be designated as Defendant No. 329. 1253. Defendant ALTERNATIVE LOAN TRUST 2006-OA10 shall be designated as Defendant No. 330. 1254. Defendant ALTERNATIVE LOAN TRUST 2006-OA11 shall be designated as Defendant No. 331. 1255. Defendant ALTERNATIVE LOAN TRUST 2006-OA12 shall be designated as Defendant No. 332. 1256. Defendant ALTERNATIVE LOAN TRUST 2006-OA14 shall be designated as Defendant No. 333. 1257. Defendant ALTERNATIVE LOAN TRUST 2006-OA16 shall be designated as Defendant No. 334. - 205 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 206 of 414 PagelD #: 972 1258. Defendant ALTERNATIVE LOAN TRUST 2006-OA17 shall be designated as Defendant No. 335. 1259. Defendant ALTERNATIVE LOAN TRUST 2006-OA18 shall be designated as Defendant No. 336. 1260. Defendant ALTERNATIVE LOAN TRUST 2006-OA19 shall be designated as Defendant No. 337. 1261. Defendant ALTERNATIVE LOAN TRUST 2006-OA2 shall be designated as Defendant No. 338. 1262. Defendant ALTERNATIVE LOAN TRUST 2006-OA21 shall be designated as Defendant No. 339. 1263. Defendant ALTERNATIVE LOAN TRUST 2006-OA21 shall be designated as Defendant No. 340. 1264. Defendant ALTERNATIVE LOAN TRUST 2006-OA22 shall be designated as Defendant No. 341. 1265. Defendant ALTERNATIVE LOAN TRUST 2006-OA3 shall be designated as Defendant No. 342. 1266. Defendant ALTERNATIVE LOAN TRUST 2006-OA6 shall be designated as Defendant No. 343. 1267. Defendant ALTERNATIVE LOAN TRUST 2006-OA7 shall be designated as Defendant No. 344. 1268. Defendant ALTERNATIVE LOAN TRUST 2006-OA7 shall be designated as Defendant No. 345. - 206 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 207 of 414 PagelD #: 973 1269. Defendant ALTERNATIVE LOAN TRUST 2006-OA8 shall be designated as Defendant No. 346. 1270. Defendant ALTERNATIVE LOAN TRUST 2006-OA8 shall be designated as Defendant No. 347. 1271. Defendant ALTERNATIVE LOAN TRUST 2006-OA9 shall be designated as Defendant No. 348. 1272. Defendant ALTERNATIVE LOAN TRUST 2006-OC1 shall be designated as Defendant No. 349. 1273. Defendant ALTERNATIVE LOAN TRUST 2006-OC1 shall be designated as Defendant No. 350. 1274. Defendant ALTERNATIVE LOAN TRUST 2006-OC10 shall be designated as Defendant No. 351. 1275. Defendant ALTERNATIVE LOAN TRUST 2006-OC11 shall be designated as Defendant No. 352. 1276. Defendant ALTERNATIVE LOAN TRUST 2006-OC2 shall be designated as Defendant No. 353. 1277. Defendant ALTERNATIVE LOAN TRUST 2006-OC3 shall be designated as Defendant No. 354. 1278. Defendant ALTERNATIVE LOAN TRUST 2006-OC4 shall be designated as Defendant No. 355. 1279. Defendant ALTERNATIVE LOAN TRUST 2006-OC6 shall be designated as Defendant No. 356. - 207 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 208 of 414 PagelD #: 974 1280. Defendant ALTERNATIVE LOAN TRUST 2006-OC7 shall be designated as Defendant No. 357. 1281. Defendant ALTERNATIVE LOAN TRUST 2006-OC7 shall be designated as Defendant No. 358. 1282. Defendant ALTERNATIVE LOAN TRUST 2006-OC8 shall be designated as Defendant No. 359. 1283. Defendant ALTERNATIVE LOAN TRUST 2006-OC9 shall be designated as Defendant No. 360. 1284. Defendant ALTERNATIVE LOAN TRUST 2007-10CB shall be designated as Defendant No. 361. 1285. Defendant ALTERNATIVE LOAN TRUST 2007- 10CB shall be designated as Defendant No. 362. 1286. Defendant ALTERNATIVE LOAN TRUST 2007-10CB shall be designated as Defendant No. 363. 1287. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 364. 1288. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 365. 1289. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 366. 1290. Defendant ALTERNATIVE LOAN TRUST 2007-12T1 shall be designated as Defendant No. 367. - 208 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 209 of 414 PagelD #: 975 1291. Defendant ALTERNATIVE LOAN TRUST 2007- 12T1 shall be designated as Defendant No. 368. 1292. Defendant ALTERNATIVE LOAN TRUST 2007- 12T1 shall be designated as Defendant No. 369. 1293. Defendant ALTERNATIVE LOAN TRUST 2007-13 shall be designated as Defendant No. 370. 1294. Defendant ALTERNATIVE LOAN TRUST 2007- 14T2 shall be designated as Defendant No. 371. 1295. Defendant ALTERNATIVE LOAN TRUST 2007- 15CB shall be designated as Defendant No. 372. 1296. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 373. 1297. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 374. 1298. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 375. 1299. Defendant ALTERNATIVE LOAN TRUST 2007- 15CB shall be designated as Defendant No. 376. 1300. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 377. 1301. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 378. - 209 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 210 of 414 PagelD #: 976 1302. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 379. 1303. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 380. 1304. Defendant ALTERNATIVE LOAN TRUST 2007-16CB shall be designated as Defendant No. 381. 1305. Defendant ALTERNATIVE LOAN TRUST 2007-16CB shall be designated as Defendant No. 382. 1306. Defendant ALTERNATIVE LOAN TRUST 2007-16CB shall be designated as Defendant No. 383. 1307. Defendant ALTERNATIVE LOAN TRUST 2007-17CB shall be designated as Defendant No. 384. 1308. Defendant ALTERNATIVE LOAN TRUST 2007-17CB shall be designated as Defendant No. 385. 1309. Defendant ALTERNATIVE LOAN TRUST 2007-18CB shall be designated as Defendant No. 386. 1310. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 387. 1311. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 388. 1312. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 389. - 210 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 211 of 414 PagelD #: 977 1313. Defendant ALTERNATIVE LOAN TRUST 2007-1T1 shall be designated as Defendant No. 390. 1314. Defendant ALTERNATIVE LOAN TRUST 2007-20 shall be designated as Defendant No. 391. 1315. Defendant ALTERNATIVE LOAN TRUST 2007-21CB shall be designated as Defendant No. 392. 1316. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 393. 1317. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 394. 1318. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 395. 1319. Defendant ALTERNATIVE LOAN TRUST 2007-23CB shall be designated as Defendant No. 396. 1320. Defendant ALTERNATIVE LOAN TRUST 2007-23CB shall be designated as Defendant No. 397. 1321. Defendant ALTERNATIVE LOAN TRUST 2007-24 shall be designated as Defendant No. 398. 1322. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 399. 1323. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 400. - 211 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 212 of 414 PagelD #: 978 1324. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 401. 1325. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 402. 1326. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 403. 1327. Defendant ALTERNATIVE LOAN TRUST 2007-2CB shall be designated as Defendant No. 404. 1328. Defendant ALTERNATIVE LOAN TRUST 2007-3T1 shall be designated as Defendant No. 405. 1329. Defendant ALTERNATIVE LOAN TRUST 2007-3T1 shall be designated as Defendant No. 406. 1330. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 407. 1331. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 408. 1332. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 409. 1333. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 410. 1334. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 411. - 212 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 213 of 414 PagelD #: 979 1335. Defendant ALTERNATIVE LOAN TRUST 2007-5CB shall be designated as Defendant No. 412. 1336. Defendant ALTERNATIVE LOAN TRUST 2007-6 shall be designated as Defendant No. 413. 1337. Defendant ALTERNATIVE LOAN TRUST 2007-7T2 shall be designated as Defendant No. 414. 1338. Defendant ALTERNATIVE LOAN TRUST 2007-7T2 shall be designated as Defendant No. 415. 1339. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 416. 1340. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 417. 1341. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 418. 1342. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 419. 1343. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 420. 1344. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 421. 1345. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 422. - 213 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 214 of 414 PagelD #: 980 1346. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 423. 1347. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 424. 1348. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 425. 1349. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 426. 1350. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 427. 1351. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 428. 1352. Defendant ALTERNATIVE LOAN TRUST 2007 -HY2 shall be designated as Defendant No. 429. 1353. Defendant ALTERNATIVE LOAN TRUST 2007-HY3 shall be designated as Defendant No. 430. 1354. Defendant ALTERNATIVE LOAN TRUST 2007-HY4 shall be designated as Defendant No. 431. 1355. Defendant ALTERNATIVE LOAN TRUST 2007-HY5R shall be designated as Defendant No. 432. 1356. Defendant ALTERNATIVE LOAN TRUST 2007-HY6 shall be designated as Defendant No. 433. - 214 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 215 of 414 PagelD #: 981 1357. Defendant ALTERNATIVE LOAN TRUST 2007-HY7C shall be designated as Defendant No. 434. 1358. Defendant ALTERNATIVE LOAN TRUST 2007-HY8C shall be designated as Defendant No. 435. 1359. Defendant ALTERNATIVE LOAN TRUST 2007-HY9 shall be designated as Defendant No. 436. 1360. Defendant ALTERNATIVE LOAN TRUST 2007-HY9 shall be designated as Defendant No. 437. 1361. Defendant ALTERNATIVE LOAN TRUST 2007- J 1 shall be designated as Defendant No. 438. 1362. Defendant ALTERNATIVE LOAN TRUST 2007- J 1 shall be designated as Defendant No. 439. 1363. Defendant ALTERNATIVE LOAN TRUST 2007- J 1 shall be designated as Defendant No. 440. 1364. Defendant ALTERNATIVE LOAN TRUST 2007- J2 shall be designated as Defendant No. 441. 1365. Defendant ALTERNATIVE LOAN TRUST 2007-J2 shall be designated as Defendant No. 442. 1366. Defendant ALTERNATIVE LOAN TRUST 2007-OA10 shall be designated as Defendant No. 443. 1367. Defendant ALTERNATIVE LOAN TRUST 2007-OA11 shall be designated as Defendant No. 444. - 215 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 216 of 414 PagelD #: 982 1368. Defendant ALTERNATIVE LOAN TRUST 2007-OA2 shall be designated as Defendant No. 445. 1369. Defendant ALTERNATIVE LOAN TRUST 2007-OA3 shall be designated as Defendant No. 446. 1370. Defendant ALTERNATIVE LOAN TRUST 2007-OA4 shall be designated as Defendant No. 447. 1371. Defendant ALTERNATIVE LOAN TRUST 2007-OA6 shall be designated as Defendant No. 448. 1372. Defendant ALTERNATIVE LOAN TRUST 2007-OA7 shall be designated as Defendant No. 449. 1373. Defendant ALTERNATIVE LOAN TRUST 2007-OA8 shall be designated as Defendant No. 450. 1374. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 451. 1375. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 452. 1376. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 453. 1377. Defendant ALTERNATIVE LOAN TRUST 2007-OH1 shall be designated as Defendant No. 454. 1378. Defendant ALTERNATIVE LOAN TRUST 2007-OH1 shall be designated as Defendant No. 455. - 216 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 217 of 414 PagelD #: 983 1379. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 456. 1380. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 457. 1381. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 458. 1382. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 459. 1383. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 460. 1384. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 461. 1385. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 462. 1386. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 463. 1387. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 464. 1388. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 465. 1389. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 466. - 217 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 218 of 414 PagelD #: 984 1390. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 467. 1391. Defendant ALTERNATIVE LOAN TRUST MORT PASS THROUGH CERT SERIES 2003-4 shall be designated as Defendant No. 468. 1392. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2005 -12R shall be designated as Defendant No. 469. 1393. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2006-22R shall be designated as Defendant No. 470. 1394. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2007-26R shall be designated as Defendant No. 471. 1395. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-1R shall be designated as Defendant No. 472. 1396. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 473. 1397. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 474. 1398. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 475. 1399. Defendant ALTERNATIVE LOAN TRUST SERIES 2003-1 shall be designated as Defendant No. 476. 1400. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-3 shall be designated as Defendant No. 477. - 218 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 219 of 414 PagelD #: 985 1401. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-5 shall be designated as Defendant No. 478. 1402. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2005-12 shall be designated as Defendant No. 479. 1403. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-1 shall be designated as Defendant No. 480. 1404. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-2 shall be designated as Defendant No. 481. 1405. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-3 shall be designated as Defendant No. 482. 1406. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-4 shall be designated as Defendant No. 483. 1407. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5 shall be designated as Defendant No. 484. 1408. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-6 shall be designated as Defendant No. 485. 1409. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-7 shall be designated as Defendant No. 486. 1410. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-8 shall be designated as Defendant No. 487. 1411. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-9 shall be designated as Defendant No. 488. - 219 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 220 of 414 PagelD #: 986 1412. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2007-1 shall be designated as Defendant No. 489. 1413. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2007-2 shall be designated as Defendant No. 490. 1414. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-10 shall be designated as Defendant No. 491. 1415. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-11 shall be designated as Defendant No. 492. 1416. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-12 shall be designated as Defendant No. 493. 1417. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-4 shall be designated as Defendant No. 494. 1418. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-5 shall be designated as Defendant No. 495. 1419. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-6 shall be designated as Defendant No. 496. - 220 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 221 of 414 PagelD #: 987 1420. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-7 shall be designated as Defendant No. 497. 1421. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-8 shall be designated as Defendant No. 498. 1422. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-9 shall be designated as Defendant No. 499. 1423. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-1 shall be designated as Defendant No. 500. 1424. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-10 shall be designated as Defendant No. 501. 1425. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-11 shall be designated as Defendant No. 502. 1426. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-2 shall be designated as Defendant No. 503. - 221 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 222 of 414 PagelD #: 988 1427. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-3 shall be designated as Defendant No. 504. 1428. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-4 shall be designated as Defendant No. 505. 1429. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-5 shall be designated as Defendant No. 506. 1430. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-6 shall be designated as Defendant No. 507. 1431. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-7 shall be designated as Defendant No. 508. 1432. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-8 shall be designated as Defendant No. 509. 1433. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-9 shall be designated as Defendant No. 510. 1434. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2003 1 1 shall be designated as Defendant No. 5 1 1 . - 222 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 223 of 414 PagelD #: 989 1435. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2004 2 shall be designated as Defendant No. 512. 1436. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 513. 1437. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 514. 1438. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 515. 1439. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 516. 1440. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 517. 1441. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 518. 1442. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 519. 1443. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 520. 1444. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 521. 1445. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 522. - 223 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 224 of 414 PagelD #: 990 1446. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 523. 1447. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 524. 1448. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 525. 1449. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 526. 1450. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 527. 1451. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 528. 1452. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 529. 1453. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 530. 1454. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 531. 1455. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 532. 1456. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 533. - 224 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 225 of 414 PagelD #: 991 1457. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 534. 1458. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 535. 1459. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 536. 1460. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 537. 1461. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 538. 1462. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 539. 1463. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 540. 1464. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 541. 1465. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 542. 1466. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 543. 1467. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 544. - 225 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 226 of 414 PagelD #: 992 1468. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2001-23 shall be designated as Defendant No. 545. 1469. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2001-23 shall be designated as Defendant No. 546. 1470. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2002-HYB1 shall be designated as Defendant No. 547. 1471. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-10 shall be designated as Defendant No. 548. 1472. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-11 shall be designated as Defendant No. 549. 1473. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-12 shall be designated as Defendant No. 550. 1474. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-13 shall be designated as Defendant No. 551. 1475. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-14 shall be designated as Defendant No. 552. 1476. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-16 shall be designated as Defendant No. 553. 1477. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-18 shall be designated as Defendant No. 554. 1478. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-19 shall be designated as Defendant No. 555. - 226 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 227 of 414 PagelD #: 993 1479. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-20 shall be designated as Defendant No. 556. 1480. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-21 shall be designated as Defendant No. 557. 1481. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-22 shall be designated as Defendant No. 558. 1482. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-23 shall be designated as Defendant No. 559. 1483. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-24 shall be designated as Defendant No. 560. 1484. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-5 shall be designated as Defendant No. 561. 1485. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-5 shall be designated as Defendant No. 562. 1486. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-6 shall be designated as Defendant No. 563. 1487. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-7 shall be designated as Defendant No. 564. 1488. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-8 shall be designated as Defendant No. 565. 1489. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-9 shall be designated as Defendant No. 566. - 227 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 228 of 414 PagelD #: 994 1490. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB7 shall be designated as Defendant No. 567. 1491. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB8 shall be designated as Defendant No. 568. 1492. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB9 shall be designated as Defendant No. 569. 1493. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-11 shall be designated as Defendant No. 570. 1494. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-12 shall be designated as Defendant No. 571. 1495. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-13 shall be designated as Defendant No. 572. 1496. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-14 shall be designated as Defendant No. 573. 1497. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-15 shall be designated as Defendant No. 574. 1498. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-16 shall be designated as Defendant No. 575. 1499. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-17 shall be designated as Defendant No. 576. 1500. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-18 shall be designated as Defendant No. 577. - 228 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 229 of 414 PagelD #: 995 1501. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-19 shall be designated as Defendant No. 578. 1502. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-20 shall be designated as Defendant No. 579. 1503. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-21 shall be designated as Defendant No. 580. 1504. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-22 shall be designated as Defendant No. 581. 1505. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-23 shall be designated as Defendant No. 582. 1506. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-24 shall be designated as Defendant No. 583. 1507. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-25 shall be designated as Defendant No. 584. 1508. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-27 shall be designated as Defendant No. 585. 1509. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-27 shall be designated as Defendant No. 586. 1510. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-27 shall be designated as Defendant No. 587. 1511. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-28 shall be designated as Defendant No. 588. - 229 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 230 of 414 PagelD #: 996 1512. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-28 shall be designated as Defendant No. 589. 1513. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-28 shall be designated as Defendant No. 590. 1514. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 591. 1515. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 592. 1516. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 593. 1517. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-3 shall be designated as Defendant No. 594. 1518. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-30 shall be designated as Defendant No. 595. 1519. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-31 shall be designated as Defendant No. 596. 1520. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-6 shall be designated as Defendant No. 597. 1521. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-9 shall be designated as Defendant No. 598. 1522. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB1 shall be designated as Defendant No. 599. - 230 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 231 of 414 PagelD #: 997 1523. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB10 shall be designated as Defendant No. 600. 1524. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB2 shall be designated as Defendant No. 601. 1525. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB3 shall be designated as Defendant No. 602. 1526. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB4 shall be designated as Defendant No. 603. 1527. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB5 shall be designated as Defendant No. 604. 1528. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB6 shall be designated as Defendant No. 605. 1529. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB7 shall be designated as Defendant No. 606. 1530. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB8 shall be designated as Defendant No. 607. 1531. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J2 shall be designated as Defendant No. 608. 1532. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J3 shall be designated as Defendant No. 609. 1533. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J4 shall be designated as Defendant No. 610. - 231 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 232 of 414 PagelD #: 998 1534. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-1 shall be designated as Defendant No. 611. 1535. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-10 shall be designated as Defendant No. 612. 1536. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-11 shall be designated as Defendant No. 613. 1537. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-12 shall be designated as Defendant No. 614. 1538. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-13 shall be designated as Defendant No. 615. 1539. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-14 shall be designated as Defendant No. 616. 1540. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-14 shall be designated as Defendant No. 617. 1541. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-15 shall be designated as Defendant No. 618. 1542. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-15 shall be designated as Defendant No. 619. 1543. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-16 shall be designated as Defendant No. 620. 1544. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-16 shall be designated as Defendant No. 621. - 232 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 233 of 414 PagelD #: 999 1545. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-16 shall be designated as Defendant No. 622. 1546. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-17 shall be designated as Defendant No. 623. 1547. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-18 shall be designated as Defendant No. 624. 1548. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-18 shall be designated as Defendant No. 625. 1549. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-18 shall be designated as Defendant No. 626. 1550. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-18 shall be designated as Defendant No. 627. 1551. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-19 shall be designated as Defendant No. 628. 1552. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-19 shall be designated as Defendant No. 629. 1553. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-20 shall be designated as Defendant No. 630. 1554. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-20 shall be designated as Defendant No. 631. 1555. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-21 shall be designated as Defendant No. 632. - 233 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 234 of 414 PagelD #: 1000 1556. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-21 shall be designated as Defendant No. 633. 1557. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-3 shall be designated as Defendant No. 634. 1558. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-6 shall be designated as Defendant No. 635. 1559. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-8 shall be designated as Defendant No. 636. 1560. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-9 shall be designated as Defendant No. 637. 1561. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB1 shall be designated as Defendant No. 638. 1562. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB2 shall be designated as Defendant No. 639. 1563. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB3 shall be designated as Defendant No. 640. 1564. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB4 shall be designated as Defendant No. 641. 1565. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB5 shall be designated as Defendant No. 642. 1566. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J1 shall be designated as Defendant No. 643. - 234 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 235 of 414 PagelD #: 1001 1567. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J2 shall be designated as Defendant No. 644. 1568. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J3 shall be designated as Defendant No. 645. 1569. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J4 shall be designated as Defendant No. 646. 1570. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-OA5 shall be designated as Defendant No. 647. 1571. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-1 shall be designated as Defendant No. 648. 1572. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-10 shall be designated as Defendant No. 649. 1573. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-11 shall be designated as Defendant No. 650. 1574. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-11 shall be designated as Defendant No. 651. 1575. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-12 shall be designated as Defendant No. 652. 1576. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-13 shall be designated as Defendant No. 653. 1577. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-13 shall be designated as Defendant No. 654. - 235 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 236 of 414 PagelD #: 1002 1578. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-14 shall be designated as Defendant No. 655. 1579. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-15 shall be designated as Defendant No. 656. 1580. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-15 shall be designated as Defendant No. 657. 1581. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-16 shall be designated as Defendant No. 658. 1582. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-16 shall be designated as Defendant No. 659. 1583. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-17 shall be designated as Defendant No. 660. 1584. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-17 shall be designated as Defendant No. 661. 1585. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-17 shall be designated as Defendant No. 662. 1586. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-17 shall be designated as Defendant No. 663. 1587. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-18 shall be designated as Defendant No. 664. 1588. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-18 shall be designated as Defendant No. 665. - 236 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 237 of 414 PagelD #: 1003 1589. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-18 shall be designated as Defendant No. 666. 1590. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-19 shall be designated as Defendant No. 667. 1591. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-19 shall be designated as Defendant No. 668. 1592. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-2 shall be designated as Defendant No. 669. 1593. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-2 shall be designated as Defendant No. 670. 1594. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-2 shall be designated as Defendant No. 671. 1595. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-20 shall be designated as Defendant No. 672. 1596. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-20 shall be designated as Defendant No. 673. 1597. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-20 shall be designated as Defendant No. 674. 1598. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-20 shall be designated as Defendant No. 675. 1599. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-21 shall be designated as Defendant No. 676. - 237 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 238 of 414 PagelD #: 1004 1600. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-21 shall be designated as Defendant No. 677. 1601. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-3 shall be designated as Defendant No. 678. 1602. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-3 shall be designated as Defendant No. 679. 1603. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-4 shall be designated as Defendant No. 680. 1604. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-4 shall be designated as Defendant No. 681. 1605. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-4 shall be designated as Defendant No. 682. 1606. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-5 shall be designated as Defendant No. 683. 1607. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-5 shall be designated as Defendant No. 684. 1608. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-5 shall be designated as Defendant No. 685. 1609. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-6 shall be designated as Defendant No. 686. 1610. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-7 shall be designated as Defendant No. 687. - 238 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 239 of 414 PagelD #: 1005 1611. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-8 shall be designated as Defendant No. 688. 1612. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-8 shall be designated as Defendant No. 689. 1613. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 690. 1614. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 691. 1615. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 692. 1616. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 693. 1617. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 694. 1618. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 695. 1619. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY1 shall be designated as Defendant No. 696. 1620. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY3 shall be designated as Defendant No. 697. 1621. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY3 shall be designated as Defendant No. 698. - 239 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 240 of 414 PagelD #: 1006 1622. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY4 shall be designated as Defendant No. 699. 1623. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY5 shall be designated as Defendant No. 700. 1624. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY6 shall be designated as Defendant No. 701. 1625. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 702. 1626. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 703. 1627. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 704. 1628. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB1 shall be designated as Defendant No. 705. 1629. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB2 shall be designated as Defendant No. 706. 1630. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB2 shall be designated as Defendant No. 707. 1631. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J1 shall be designated as Defendant No. 708. 1632. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J1 shall be designated as Defendant No. 709. - 240 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 241 of 414 PagelD #: 1007 1633. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 710. 1634. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 711. 1635. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 712. 1636. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 713. 1637. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 714. 1638. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 715. 1639. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 716. 1640. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 717. 1641. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 718. 1642. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 719. 1643. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 720. - 241 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 242 of 414 PagelD #: 1008 1644. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J3 shall be designated as Defendant No. 721. 1645. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2008-1 shall be designated as Defendant No. 722. 1646. Defendant CHL MORTGAGE PASS-THROUGH TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 723. 1647. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB5 shall be designated as Defendant No. 724. 1648. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004- J7 shall be designated as Defendant No. 725. 1649. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-J8 shall be designated as Defendant No. 726. 1650. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-J9 shall be designated as Defendant No. 727. 1651. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2004- 25 shall be designated as Defendant No. 728. 1652. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2004- 29 shall be designated as Defendant No. 729. 1653. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 2 shall be designated as Defendant No. 730. 1654. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 4 shall be designated as Defendant No. 731. - 242 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 243 of 414 PagelD #: 1009 1655. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 5 shall be designated as Defendant No. 732. 1656. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2002- 21 shall be designated as Defendant No. 733. 1657. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2002- 21 shall be designated as Defendant No. 734. 1658. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 735. 1659. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 736. 1660. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 737. 1661. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 738. 1662. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 739. 1663. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 26 shall be designated as Defendant No. 740. 1664. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 26 shall be designated as Defendant No. 741. 1665. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003-3 shall be designated as Defendant No. 742. - 243 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 244 of 414 PagelD #: 1010 1666. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 42 shall be designated as Defendant No. 743. 1667. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 42 shall be designated as Defendant No. 744. 1668. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 48 shall be designated as Defendant No. 745. 1669. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2004- J3 shall be designated as Defendant No. 746. 1670. Defendant CWMBS, INC. - CHL MORTGAGE PASS-THROUGH TRUST 2005-1 shall be designated as Defendant No. 747. 1671. Defendant CWMBS, INC. - CHL MORTGAGE PASS-THROUGH TRUST 2005-7 shall be designated as Defendant No. 748. 1672. Defendant CWMBS, INC., CHL MORTGAGE PASS-THROUGH TRUST 2005- 26 shall be designated as Defendant No. 749. 1673. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-3 shall be designated as Defendant No. 750. 1674. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-5 shall be designated as Defendant No. 751. 1675. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-1 shall be designated as Defendant No. 752. 1676. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-2 shall be designated as Defendant No. 753. - 244 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 245 of 414 PagelD #: 1011 1677. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-3 shall be designated as Defendant No. 754. 1678. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-4 shall be designated as Defendant No. 755. 1679. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5 shall be designated as Defendant No. 756. 1680. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-8 shall be designated as Defendant No. 757. 1681. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-9 shall be designated as Defendant No. 758. 1682. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-10 shall be designated as Defendant No. 759. 1683. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-11 shall be designated as Defendant No. 760. 1684. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-12 shall be designated as Defendant No. 761. 1685. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-4 shall be designated as Defendant No. 762. - 245 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 246 of 414 PagelD #: 1012 1686. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-5 shall be designated as Defendant No. 763. 1687. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-6 shall be designated as Defendant No. 764. 1688. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-7 shall be designated as Defendant No. 765. 1689. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-8 shall be designated as Defendant No. 766. 1690. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-9 shall be designated as Defendant No. 767. 1691. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-1 shall be designated as Defendant No. 768. 1692. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-10 shall be designated as Defendant No. 769. - 246 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 247 of 414 PagelD #: 1013 1693. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-11 shall be designated as Defendant No. 770. 1694. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-2 shall be designated as Defendant No. 771. 1695. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-3 shall be designated as Defendant No. 772. 1696. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-4 shall be designated as Defendant No. 773. 1697. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-5 shall be designated as Defendant No. 774. 1698. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-6 shall be designated as Defendant No. 775. 1699. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-7 shall be designated as Defendant No. 776. - 247 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 248 of 414 PagelD #: 1014 1700. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-8 shall be designated as Defendant No. 777. 1701. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-9 shall be designated as Defendant No. 778. 1702. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2003 1 1 shall be designated as Defendant No. 779. 1703. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2004 2 shall be designated as Defendant No. 780. 1704. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVER LOAN TRUST 2003-10 shall be designated as Defendant No. 781. 1705. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 782. 1706. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-3, ASSET- BACKED CERTS., SERIES 2004-3 shall be designated as Defendant No. 783. 1707. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-4, ASSET- BACKED CERTS., SERIES 2004-4 shall be designated as Defendant No. 784. 1708. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-5, ASSET- BACKED CERTS., SERIES 2004-5 shall be designated as Defendant No. 785. 1709. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-6, ASSET- BACKED CERTS., SERIES 2004-6 shall be designated as Defendant No. 786. - 248 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 249 of 414 PagelD #: 1015 1710. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-1, ASSET- BACKED CERTS., SERIES 2005-1 shall be designated as Defendant No. 787. 1711. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-2 ASSET- BACKED CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 788. 1712. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-3 ASSET- BACKED CERTIFICATES, SERIES 2005-3 shall be designated as Defendant No. 789. 1713. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL1 ASSET- BACKED CERTIFICATES, SERIES 2005-WL1 shall be designated as Defendant No. 790. 1714. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL2 ASSET- BACKED CERTIFICATES shall be designated as Defendant No. 791. 1715. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL3 shall be designated as Defendant No. 792. 1716. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-1 shall be designated as Defendant No. 793. 1717. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-1 shall be designated as Defendant No. 794. 1718. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-10 shall be designated as Defendant No. 795. 1719. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-10 shall be designated as Defendant No. 796. - 249 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 250 of 414 PagelD #: 1016 1720. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 797. 1721. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 798. 1722. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 799. 1723. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 800. 1724. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 801. 1725. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 802. 1726. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 803. 1727. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 804. 1728. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 805. 1729. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 806. 1730. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 807. - 250 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 251 of 414 PagelD #: 1017 1731. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 808. 1732. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-5 shall be designated as Defendant No. 809. 1733. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-5 shall be designated as Defendant No. 810. 1734. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-6 shall be designated as Defendant No. 811. 1735. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-6 shall be designated as Defendant No. 812. 1736. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 813. 1737. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 814. 1738. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 815. 1739. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-8 shall be designated as Defendant No. 816. 1740. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-8 shall be designated as Defendant No. 817. 1741. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-9 shall be designated as Defendant No. 818. - 251 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 252 of 414 PagelD #: 1018 1742. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-9 shall be designated as Defendant No. 819. 1743. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-A shall be designated as Defendant No. 820. 1744. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-A shall be designated as Defendant No. 821. 1745. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL1 shall be designated as Defendant No. 822. 1746. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL1 shall be designated as Defendant No. 823. 1747. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL2 shall be designated as Defendant No. 824. 1748. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL2 shall be designated as Defendant No. 825. 1749. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL3 shall be designated as Defendant No. 826. 1750. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL3 shall be designated as Defendant No. 827. 175 1 . Defendant LONG BEACH SECURITIES CORP shall be designated as Defendant No. 828. 1752. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE1 shall be designated as Defendant No. 829. - 252 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 253 of 414 PagelD #: 1019 1753. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE2 shall be designated as Defendant No. 830. 1754. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE3 shall be designated as Defendant No. 831. 1755. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE4 shall be designated as Defendant No. 832. 1756. Defendant WAMU MOR PASS THRU CERT SER 2001-AR1 shall be designated as Defendant No. 833. 1757. Defendant WAMU MORTAGE PASS THRU CERT SER 2003-S8 shall be designated as Defendant No. 834. 1758. Defendant WAMU MORTAGE PASS THRU CERT SERIES 2003-AR3 shall be designated as Defendant No. 835. 1759. Defendant WAMU MORTGAGE PASS THR CERTS SER 2003-AR12 shall be designated as Defendant No. 836. 1760. Defendant WAMU MORTGAGE PASS THROUGH CER SER 2003-AR8 shall be designated as Defendant No. 837. 1761. Defendant WAMU MORTGAGE PASS THROUGH CERT 2002-AR10 shall be designated as Defendant No. 838. 1762. Defendant WAMU MORTGAGE PASS THROUGH CERT 2002-AR10 shall be designated as Defendant No. 839. 1763. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2002-AR19 shall be designated as Defendant No. 840. - 253 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 254 of 414 PagelD #: 1020 1764. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2002-AR19 shall be designated as Defendant No. 841. 1765. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2003-S1 shall be designated as Defendant No. 842. 1766. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2001-5 shall be designated as Defendant No. 843. 1767. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2001-S8 shall be designated as Defendant No. 844. 1768. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2002-S8 shall be designated as Defendant No. 845. 1769. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2002-S8 shall be designated as Defendant No. 846. 1770. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S1 shall be designated as Defendant No. 847. 1771. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S1 shall be designated as Defendant No. 848. 1772. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S7 shall be designated as Defendant No. 849. 1773. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S7 shall be designated as Defendant No. 850. 1774. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR2 shall be designated as Defendant No. 851. - 254 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 255 of 414 PagelD #: 1021 1775. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR3 shall be designated as Defendant No. 852. 1776. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR4 shall be designated as Defendant No. 853. 1777. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001- S11 shall be designated as Defendant No. 854. 1778. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR12 shall be designated as Defendant No. 855. 1779. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR12 shall be designated as Defendant No. 856. 1780. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR14 shall be designated as Defendant No. 857. 1781. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR14 shall be designated as Defendant No. 858. 1782. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002- AR1 1 shall be designated as Defendant No. 859. 1783. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR13 shall be designated as Defendant No. 860. 1784. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR13 shall be designated as Defendant No. 861. 1785. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR15 shall be designated as Defendant No. 862. - 255 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 256 of 414 PagelD #: 1022 1786. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR15 shall be designated as Defendant No. 863. 1787. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR16 shall be designated as Defendant No. 864. 1788. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR17 shall be designated as Defendant No. 865. 1789. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR17 shall be designated as Defendant No. 866. 1790. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR3 shall be designated as Defendant No. 867. 1791. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR3 shall be designated as Defendant No. 868. 1792. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S2 shall be designated as Defendant No. 869. 1793. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S2 shall be designated as Defendant No. 870. 1794. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S3 shall be designated as Defendant No. 871. 1795. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S3 shall be designated as Defendant No. 872. 1796. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S4 shall be designated as Defendant No. 873. - 256 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 257 of 414 PagelD #: 1023 1797. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S6 shall be designated as Defendant No. 874. 1798. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002- S6 shall be designated as Defendant No. 875. 1799. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003 S3 shall be designated as Defendant No. 876. 1800. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003 S4 shall be designated as Defendant No. 877. 1801. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003- AR1 shall be designated as Defendant No. 878. 1802. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR4 shall be designated as Defendant No. 879. 1803. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR5 shall be designated as Defendant No. 880. 1804. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR6 shall be designated as Defendant No. 881. 1805. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-S2 shall be designated as Defendant No. 882. 1806. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-AR10 shall be designated as Defendant No. 883. 1807. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S10 shall be designated as Defendant No. 884. - 257 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 258 of 414 PagelD #: 1024 1808. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S11 shall be designated as Defendant No. 885. 1809. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S9 shall be designated as Defendant No. 886. 1810. Defendant WAMU MORTGAGE PASS THROUGH CERTS SERIES 2003-S5 shall be designated as Defendant No. 887. 1811. Defendant WAMU MORTGAGE PASS THROUGH CERTS SERIES 2004-S1 shall be designated as Defendant No. 888. 1812. Defendant WAMU MORTGAGE PASS THRU CERTIFICATE SERIES 2001- AR6 shall be designated as Defendant No. 889. 1813. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS8 shall be designated as Defendant No. 890. 1814. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS8 shall be designated as Defendant No. 891. 1815. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS9 shall be designated as Defendant No. 892. 1816. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS9 shall be designated as Defendant No. 893. 1817. Defendant WAMU MORTGAGE PASS THRU CERTS SERIES 2002-ARS shall be designated as Defendant No. 894. 1818. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2002-AR4 shall be designated as Defendant No. 895. - 258 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 259 of 414 PagelD #: 1025 1819. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2002- AR4 shall be designated as Defendant No. 896. 1820. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SER 2003- S12 shall be designated as Defendant No. 897. 1821. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2001-S10 shall be designated as Defendant No. 898. 1822. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2003- S7 shall be designated as Defendant No. 899. 1823. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004 AR-3 shall be designated as Defendant No. 900. 1824. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR1 shall be designated as Defendant No. 901. 1825. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR2 shall be designated as Defendant No. 902. 1826. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR4 shall be designated as Defendant No. 903. 1827. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR6 shall be designated as Defendant No. 904. 1828. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-CB1 shall be designated as Defendant No. 905. 1829. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-RS2 shall be designated as Defendant No. 906. - 259 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 260 of 414 PagelD #: 1026 1830. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-S2 shall be designated as Defendant No. 907. 1831. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR 10 shall be designated as Defendant No. 908. 1832. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR11 shall be designated as Defendant No. 909. 1833. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR11 shall be designated as Defendant No. 910. 1834. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR12 shall be designated as Defendant No. 911. 1835. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR13 shall be designated as Defendant No. 912. 1836. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR14 shall be designated as Defendant No. 913. 1837. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR5 shall be designated as Defendant No. 914. 1838. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR7 shall be designated as Defendant No. 915. 1839. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR8 shall be designated as Defendant No. 916. 1840. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR9 shall be designated as Defendant No. 917. - 260 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 261 of 414 PagelD #: 1027 1841. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB2 shall be designated as Defendant No. 918. 1842. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB3 shall be designated as Defendant No. 919. 1843. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB4 shall be designated as Defendant No. 920. 1844. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- S3 shall be designated as Defendant No. 921. 1845. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005- AR1 shall be designated as Defendant No. 922. 1846. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR1 shall be designated as Defendant No. 923. 1847. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR10 shall be designated as Defendant No. 924. 1848. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR11 shall be designated as Defendant No. 925. 1849. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR1 1 shall be designated as Defendant No. 926. 1850. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR12 shall be designated as Defendant No. 927. 1851. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR13 shall be designated as Defendant No. 928. - 261 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 262 of 414 PagelD #: 1028 1852. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR13 shall be designated as Defendant No. 929. 1853. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR14 shall be designated as Defendant No. 930. 1854. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR15 shall be designated as Defendant No. 931. 1855. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR16 shall be designated as Defendant No. 932. 1856. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR17 shall be designated as Defendant No. 933. 1857. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR18 shall be designated as Defendant No. 934. 1858. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR19 shall be designated as Defendant No. 935. 1859. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR2 shall be designated as Defendant No. 936. 1860. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR2 shall be designated as Defendant No. 937. 1861. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR3 shall be designated as Defendant No. 938. 1862. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR4 shall be designated as Defendant No. 939. - 262 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 263 of 414 PagelD #: 1029 1863. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR5 shall be designated as Defendant No. 940. 1864. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR6 shall be designated as Defendant No. 941. 1865. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR6 shall be designated as Defendant No. 942. 1866. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR7 shall be designated as Defendant No. 943. 1867. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR8 shall be designated as Defendant No. 944. 1868. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR8 shall be designated as Defendant No. 945. 1869. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR9 shall be designated as Defendant No. 946. 1870. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005- AR9 shall be designated as Defendant No. 947. 1871. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006- AR1 shall be designated as Defendant No. 948. 1872. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR10 shall be designated as Defendant No. 949. 1873. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR1 1 shall be designated as Defendant No. 950. - 263 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 264 of 414 PagelD #: 1030 1874. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR12 shall be designated as Defendant No. 951. 1875. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR13 shall be designated as Defendant No. 952. 1876. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR14 shall be designated as Defendant No. 953. 1877. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR15 shall be designated as Defendant No. 954. 1878. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR16 shall be designated as Defendant No. 955. 1879. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR17 shall be designated as Defendant No. 956. 1880. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR18 shall be designated as Defendant No. 957. 1881. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR19 shall be designated as Defendant No. 958. 1882. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR2 shall be designated as Defendant No. 959. 1883. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR3 shall be designated as Defendant No. 960. 1884. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR4 shall be designated as Defendant No. 961. - 264 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 265 of 414 PagelD #: 1031 1885. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR5 shall be designated as Defendant No. 962. 1886. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR6 shall be designated as Defendant No. 963. 1887. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR7 shall be designated as Defendant No. 964. 1888. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR8 shall be designated as Defendant No. 965. 1889. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006- AR9 shall be designated as Defendant No. 966. 1890. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007- HY1 shall be designated as Defendant No. 967. 1891. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY2 shall be designated as Defendant No. 968. 1892. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY3 shall be designated as Defendant No. 969. 1893. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY4 shall be designated as Defendant No. 970. 1894. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY5 shall be designated as Defendant No. 971. 1895. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY6 shall be designated as Defendant No. 972. - 265 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 266 of 414 PagelD #: 1032 1896. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY7 shall be designated as Defendant No. 973. 1897. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA1 shall be designated as Defendant No. 974. 1898. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA2 shall be designated as Defendant No. 975. 1899. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA3 shall be designated as Defendant No. 976. 1900. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA4 shall be designated as Defendant No. 977. 1901. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA5 shall be designated as Defendant No. 978. 1902. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA6 shall be designated as Defendant No. 979. 1903. Defendant WAMU MORTGAGE PASS-THRU CERT SERIES 2003-AR2 shall be designated as Defendant No. 980. 1904. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 02 AR7 shall be designated as Defendant No. 981. 1905. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 02 AR7 shall be designated as Defendant No. 982. 1906. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 03 S6 shall be designated as Defendant No. 983. - 266 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 267 of 414 PagelD #: 1033 1907. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002 S5 shall be designated as Defendant No. 984. 1908. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002 S5 shall be designated as Defendant No. 985. 1909. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002- AR9 shall be designated as Defendant No. 986. 1910. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002- AR9 shall be designated as Defendant No. 987. 1911. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CER SE 02 AR18 shall be designated as Defendant No. 988. 1912. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CER SE 02 AR18 shall be designated as Defendant No. 989. 1913. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 AR9 shall be designated as Defendant No. 990. 1914. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 AR9 shall be designated as Defendant No. 991. 1915. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 S13 shall be designated as Defendant No. 992. 1916. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MOR PAS TH CE SE 03 AR7 shall be designated as Defendant No. 993. 1917. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU SERIES 2003-AR1 1 shall be designated as Defendant No. 994. - 267 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 268 of 414 PagelD #: 1034 1918. Defendant WASHINGTON MUTUAL MORT SEC WAMU MOR PA TH CE SE 2002 AR2 shall be designated as Defendant No. 995. 1919. Defendant AMERIQUEST MORTGAGE SECURITIES INC shall be designated as Defendant No. 996. 1920. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R4 shall be designated as Defendant No. 997. 1921. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R6 shall be designated as Defendant No. 998. 1922. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R7 shall be designated as Defendant No. 999. 1923. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R8 shall be designated as Defendant No. 1000. 1924. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R9 shall be designated as Defendant No. 1001. 1925. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-IA1 shall be designated as Defendant No. 1002. - 268 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 269 of 414 PagelD #: 1035 1926. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R10 shall be designated as Defendant No. 1003. 1927. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R11 shall be designated as Defendant No. 1004. 1928. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-1 shall be designated as Defendant No. 1005. 1929. Defendant AMERIQUEST MORTGAGE SECURnTES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-6 shall be designated as Defendant No. 1006. 1930. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR2 shall be designated as Defendant No. 1007. 1931. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR3 shall be designated as Defendant No. 1008. 1932. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R10 shall be designated as Defendant No. 1009. - 269 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 270 of 414 PagelD #: 1036 1933. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R5 shall be designated as Defendant No. 1010. 1934. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R6 shall be designated as Defendant No. 1011. 1935. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R7 shall be designated as Defendant No. 1012. 1936. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R8 shall be designated as Defendant No. 1013. 1937. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R9 shall be designated as Defendant No. 1014. 1938. Defendant AMERIQUEST MORTGAGE SECURITIES TRUST 2006-R1, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-R1 shall be designated as Defendant No. 1015. 1939. Defendant ARGENT SECURITIES INC shall be designated as Defendant No. 1016. 1940. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-W7 shall be designated as Defendant No. 1017. - 270 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 271 of 414 PagelD #: 1037 1941. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-PW1 shall be designated as Defendant No. 1018. 1942. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-W10 shall be designated as Defendant No. 1019. 1943. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-W1 1 shall be designated as Defendant No. 1020. 1944. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004- W9 shall be designated as Defendant No. 1021. 1945. Defendant ARGENT SECURITIES INC. , ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-W1 shall be designated as Defendant No. 1022. 1946. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W2 shall be designated as Defendant No. 1023. 1947. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W3 shall be designated as Defendant No. 1024. 1948. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W4 shall be designated as Defendant No. 1025. 1949. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W5 shall be designated as Defendant No. 1026. 1950. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-W2 shall be designated as Defendant No. 1027. 1951. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2003-W7 shall be designated as Defendant No. 1028. - 271 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 272 of 414 PagelD #: 1038 1952. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2003- W7 shall be designated as Defendant No. 1029. 1953. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004- R2 shall be designated as Defendant No. 1030. 1954. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004- W1 shall be designated as Defendant No. 1031. 1955. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2005- R2 shall be designated as Defendant No. 1032. 1956. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R12 shall be designated as Defendant No. 1033. 1957. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004- R5 shall be designated as Defendant No. 1034. 1958. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005- R4 shall be designated as Defendant No. 1035. 1959. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R4 shall be designated as Defendant No. 1036. 1960. Defendant CARRINGTON HOME EQUITY LOAN TRUST, SERIES 2005-NC4 ASSET-BACKED PASS-THROUGH CERTIFICATES shall be designated as Defendant No. 1037. 1961. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE1, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WFHE1 shall be designated as Defendant No. 1038. - 272 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 273 of 414 PagelD #: 1039 1962. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1039. 1963. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1040. 1964. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1041. 1965. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1042. 1966. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WMC1 shall be designated as Defendant No. 1043. 1967. Defendant GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1044. 1968. Defendant HOMESTAR MORTGAGE ACCEPTANCE CORP ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-4 shall be designated as Defendant No. 1045. 1969. Defendant MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-QS9 shall be designated as Defendant No. 1046. 1970. Defendant MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-QS9 shall be designated as Defendant No. 1047. - 273 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 274 of 414 PagelD #: 1040 1971. Defendant OPTEUM MORTGAGE ACCEPTANCE CORP shall be designated as Defendant No. 1048. 1972. Defendant OPTEUM MORTGAGE ACCEPTANCE CORP. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-4 shall be designated as Defendant No. 1049. 1973. Defendant PARK PLACE SECURITIES INC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCW1 shall be designated as Defendant No. 1050. 1974. Defendant PARK PLACE SECURITIES, INC. shall be designated as Defendant No. 1051. 1975. Defendant PARK PLACE SECURITIES, INC. ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-MCW1 shall be designated as Defendant No. 1052. 1976. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-MHQ1 shall be designated as Defendant No. 1053. 1977. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCH1 shall be designated as Defendant No. 1054. 1978. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCW2 shall be designated as Defendant No. 1055. - 274 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 275 of 414 PagelD #: 1041 1979. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004- WHQ1 shall be designated as Defendant No. 1056. 1980. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WHQ2 shall be designated as Defendant No. 1057. 1981. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WWF1 shall be designated as Defendant No. 1058. 1982. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW2 shall be designated as Defendant No. 1059. 1983. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW2 shall be designated as Defendant No. 1060. 1984. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW3 shall be designated as Defendant No. 1061. 1985. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ1 shall be designated as Defendant No. 1062. - 275 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 276 of 414 PagelD #: 1042 1986. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ1 shall be designated as Defendant No. 1063. 1987. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ4 shall be designated as Defendant No. 1064. 1988. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WLL1 shall be designated as Defendant No. 1065. 1989. Defendant AMERICAN HOME MORT SECURITIES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1066. 1990. Defendant AMERICAN HOME MORT SECURnTES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1067. 1991. Defendant AMERICAN HOME MORT SECUTIES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1068. 1992. Defendant AMERICAN HOME MORTGAGE ASSETS LLC shall be designated as Defendant No. 1069. 1993. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2005-1 shall be designated as Defendant No. 1070. 1994. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2005-2 shall be designated as Defendant No. 1071. 1995. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-1 shall be designated as Defendant No. 1072. - 276 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 277 of 414 PagelD #: 1043 1996. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-2 shall be designated as Defendant No. 1073. 1997. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-2 shall be designated as Defendant No. 1074. 1998. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-3 shall be designated as Defendant No. 1075. 1999. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-4 shall be designated as Defendant No. 1076. 2000. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-4 shall be designated as Defendant No. 1077. 2001. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-5 shall be designated as Defendant No. 1078. 2002. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-6 shall be designated as Defendant No. 1079. 2003. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-1 shall be designated as Defendant No. 1080. 2004. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-2 shall be designated as Defendant No. 1081. 2005. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-3 shall be designated as Defendant No. 1082. 2006. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-4 shall be designated as Defendant No. 1083. - 277 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 278 of 414 PagelD #: 1044 2007. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-4 shall be designated as Defendant No. 1084. 2008. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-5 shall be designated as Defendant No. 1085. 2009. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1086. 2010. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1087. 2011. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1088. 2012. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1089. 2013. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1090. 2014. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1091. 2015. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1092. 2016. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1093. 2017. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1094. - 278 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 279 of 414 PagelD #: 1045 2018. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1095. 2019. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1096. 2020. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1097. 2021. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1098. 2022. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1099. 2023. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1 100. 2024. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-3 shall be designated as Defendant No. 1 101. 2025. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-3 shall be designated as Defendant No. 1 102. 2026. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-3 shall be designated as Defendant No. 1 103. 2027. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 shall be designated as Defendant No. 1 104. 2028. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 shall be designated as Defendant No. 1 105. - 279 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 280 of 414 PagelD #: 1046 2029. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 shall be designated as Defendant No. 1 106. 2030. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 shall be designated as Defendant No. 1 107. 2031. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-4 shall be designated as Defendant No. 1 108. 2032. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-1 shall be designated as Defendant No. 1 109. 2033. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-1 shall be designated as Defendant No. 1 1 10. 2034. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-1 shall be designated as Defendant No. 1111. 2035. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-1 shall be designated as Defendant No. 1 1 12. 2036. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-2 shall be designated as Defendant No. 1113. 2037. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-2 shall be designated as Defendant No. 1 1 14. 2038. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-2 shall be designated as Defendant No. 1 1 15. 2039. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-3 shall be designated as Defendant No. 1116. - 280 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 281 of 414 PagelD #: 1047 2040. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-4 shall be designated as Defendant No. 1 1 17. 2041. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-4 shall be designated as Defendant No. 1118. 2042. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-4 shall be designated as Defendant No. 1 1 19. 2043. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-4 shall be designated as Defendant No. 1 120. 2044. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-1 shall be designated as Defendant No. 1121. 2045. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-2 shall be designated as Defendant No. 1 122. 2046. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-2 shall be designated as Defendant No. 1 123. 2047. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-3 shall be designated as Defendant No. 1 124. 2048. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-1 shall be designated as Defendant No. 1 125. 2049. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 126. 2050. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 127. - 281 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 282 of 414 PagelD #: 1048 2051. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 128. 2052. Defendant CITICORP MORTGAGE SEC INC REMIC CER SERIES 2003-9 shall be designated as Defendant No. 1 129. 2053. Defendant CITICORP MORTGAGE SEC INC REMIC PASS THR CER SER 2003-3 shall be designated as Defendant No. 1 130. 2054. Defendant CITICORP MORTGAGE SEC INC REMIC PASS THR CERTS SERIES 2003 5 shall be designated as Defendant No. 1131. 2055. Defendant CITICORP MORTGAGE SEC INC REMIC PASS-THR CERT SER 2003-4 shall be designated as Defendant No. 1 132. 2056. Defendant CITICORP MORTGAGE SECURITIES INC shall be designated as Defendant No. 1133. 2057. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-1 shall be designated as Defendant No. 1 134. 2058. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-2 shall be designated as Defendant No. 1 135. 2059. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-3 shall be designated as Defendant No. 1 136. 2060. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-4 shall be designated as Defendant No. 1 137. 2061. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-5 shall be designated as Defendant No. 1 138. - 282 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 283 of 414 PagelD #: 1049 2062. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-6 shall be designated as Defendant No. 1 139. 2063. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-7 shall be designated as Defendant No. 1 140. 2064. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-1 shall be designated as Defendant No. 1 141. 2065. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-2 shall be designated as Defendant No. 1 142. 2066. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-2 shall be designated as Defendant No. 1 143. 2067. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-3 shall be designated as Defendant No. 1 144. 2068. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-4 shall be designated as Defendant No. 1 145. 2069. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-5 shall be designated as Defendant No. 1 146. 2070. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-6 shall be designated as Defendant No. 1 147. 2071. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-7 shall be designated as Defendant No. 1 148. 2072. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-7 shall be designated as Defendant No. 1 149. - 283 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 284 of 414 PagelD #: 1050 2073. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-7 shall be designated as Defendant No. 1 150. 2074. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-8 shall be designated as Defendant No. 1151. 2075. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-9 shall be designated as Defendant No. 1 152. 2076. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2008-1 shall be designated as Defendant No. 1 153. 2077. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2008-2 shall be designated as Defendant No. 1 154. 2078. Defendant CITICORP RESIDENTIAL MORTGAGE SECURITIES, INC. shall be designated as Defendant No. 1 155. 2079. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-1 shall be designated as Defendant No. 1 156. 2080. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-1 shall be designated as Defendant No. 1 157. 2081. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-2 shall be designated as Defendant No. 1 158. 2082. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-2 shall be designated as Defendant No. 1 159. 2083. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-3 shall be designated as Defendant No. 1 160. - 284 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 285 of 414 PagelD #: 1051 2084. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-3 shall be designated as Defendant No. 1161. 2085. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-1 shall be designated as Defendant No. 1 162. 2086. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-1 shall be designated as Defendant No. 1 163. 2087. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-2 shall be designated as Defendant No. 1 164. 2088. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-2 shall be designated as Defendant No. 1 165. 2089. Defendant CITIGROUP MORT LN TR ASST BACK PS THR CERTS SER 2003-HE3 shall be designated as Defendant No. 1 166. 2090. Defendant CITIGROUP MORT LOAN TRUST INC ASSET BK PAS THR CE SE 03 HE2 shall be designated as Defendant No. 1 167. 209 1 . Defendant CITIGROUP MORT LOAN TRUST INC MORT PAS THR CERT SE 03 1 shall be designated as Defendant No. 1 168. 2092. Defendant CITIGROUP MORTGAG LOAN TRUST SERIES 2003-UP3 shall be designated as Defendant No. 1 169. 2093. Defendant CITIGROUP MORTGAGE LOAN TRUST 2005-11 shall be designated as Defendant No. 1 170. 2094. Defendant CITIGROUP MORTGAGE LOAN TRUST 2005-6 shall be designated as Defendant No. 1171. - 285 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 286 of 414 PagelD #: 1052 2095. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 172. 2096. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 173. 2097. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 174. 2098. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006- AMC1 shall be designated as Defendant No. 1175. 2099. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-AR1 shall be designated as Defendant No. 1 176. 2100. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-AR5 shall be designated as Defendant No. 1 177. 2101. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-AR6 shall be designated as Defendant No. 1178. 2102. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-AR7 shall be designated as Defendant No. 1 179. 2103. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-AR9 shall be designated as Defendant No. 1 180. 2104. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-CB3 shall be designated as Defendant No. 1181. 2105. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-FX1 shall be designated as Defendant No. 1 182. - 286 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 287 of 414 PagelD #: 1053 2106. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-HE1 shall be designated as Defendant No. 1 183. 2107. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-HE2 shall be designated as Defendant No. 1 184. 2108. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-HE3 shall be designated as Defendant No. 1 185. 2109. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-NC1 shall be designated as Defendant No. 1 186. 2110. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-NC2 shall be designated as Defendant No. 1 187. 2111. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WF1 shall be designated as Defendant No. 1 188. 2112. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WF2 shall be designated as Defendant No. 1 189. 2113. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE1, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WFHE1 shall be designated as Defendant No. 1 190. 2114. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE2 shall be designated as Defendant No. 1191. 2115. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE3 shall be designated as Defendant No. 1 192. 2116. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 shall be designated as Defendant No. 1 193. - 287 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 288 of 414 PagelD #: 1054 2117. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 194. 2118. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 195. 2119. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 196. 2120. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 197. 2121. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 198. 2122. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-2 shall be designated as Defendant No. 1 199. 2123. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-6 shall be designated as Defendant No. 1200. 2124. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-6 shall be designated as Defendant No. 1201. 2125. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-8 shall be designated as Defendant No. 1202. 2126. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AHL1 shall be designated as Defendant No. 1203. 2127. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AHL2 shall be designated as Defendant No. 1204. - 288 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 289 of 414 PagelD #: 1055 2128. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AHL3 shall be designated as Defendant No. 1205. 2129. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AMC1 shall be designated as Defendant No. 1206. 2130. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AMC2 shall be designated as Defendant No. 1207. 2131. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AMC3 shall be designated as Defendant No. 1208. 2132. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AMC4 shall be designated as Defendant No. 1209. 2133. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AR1 shall be designated as Defendant No. 1210. 2134. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AR4 shall be designated as Defendant No. 1211. 2135. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007- AR5 shall be designated as Defendant No. 1212. 2136. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-CB3 shall be designated as Defendant No. 1213. 2137. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-OPX1 shall be designated as Defendant No. 1214. 2138. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE1 shall be designated as Defendant No. 1215. - 289 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 290 of 414 PagelD #: 1056 2139. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE2 shall be designated as Defendant No. 1216. 2140. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE3 shall be designated as Defendant No. 1217. 2141. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE4 shall be designated as Defendant No. 1218. 2142. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1219. 2143. Defendant CITIGROUP MORTGAGE LOAN TRUST INC CARRINGTON MORTGAGE LOAN TRUST, SERIES 2004-NC2 shall be designated as Defendant No. 1220. 2144. Defendant CITIGROUP MORTGAGE LOAN TRUST INC C-BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2004-CB7 shall be designated as Defendant No. 1221. 2145. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-HYB3 shall be designated as Defendant No. 1222. 2146. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004- NCM2 shall be designated as Defendant No. 1223. 2147. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-OPT1 shall be designated as Defendant No. 1224. 2148. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-UST1 shall be designated as Defendant No. 1225. - 290 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 291 of 414 PagelD #: 1057 2149. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-UST1 shall be designated as Defendant No. 1226. 2150. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2005 -OPT 1 shall be designated as Defendant No. 1227. 2151. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2005-OPT2 shall be designated as Defendant No. 1228. 2152. Defendant CITIGROUP MORTGAGE LOAN TRUST INC, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-1 shall be designated as Defendant No. 1229. 2153. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. 2005-4 shall be designated as Defendant No. 1230. 2154. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. 2005-7 shall be designated as Defendant No. 1231. 2155. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1232. 2156. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1233. 2157. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1234. - 291 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 292 of 414 PagelD #: 1058 2158. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1235. 2159. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-NCM1 shall be designated as Defendant No. 1236. 2160. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1237. 2161. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1238. 2162. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. SERIES 2004 - HYB4 shall be designated as Defendant No. 1239. 2163. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WMC1 shall be designated as Defendant No. 1240. 2164. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-3 shall be designated as Defendant No. 1241. 2165. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-3 shall be designated as Defendant No. 1242. 2166. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-5 shall be designated as Defendant No. 1243. - 292 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 293 of 414 PagelD #: 1059 2167. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-8 shall be designated as Defendant No. 1244. 2168. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-9 shall be designated as Defendant No. 1245. 2169. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-HE3 shall be designated as Defendant No. 1246. 2170. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-HE4 shall be designated as Defendant No. 1247. 2171. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR2 shall be designated as Defendant No. 1248. 2172. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR3 shall be designated as Defendant No. 1249. 2173. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR3 shall be designated as Defendant No. 1250. 2174. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2007-AR7 shall be designated as Defendant No. 1251. 2175. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2003 UST-1 shall be designated as Defendant No. 1252. 2176. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-CB3 shall be designated as Defendant No. 1253. 2177. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-HYB1 shall be designated as Defendant No. 1254. - 293 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 294 of 414 PagelD #: 1060 2178. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-HYB2 shall be designated as Defendant No. 1255. 2179. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2004-RES1 shall be designated as Defendant No. 1256. 2180. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-10 shall be designated as Defendant No. 1257. 2181. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-CB4 shall be designated as Defendant No. 1258. 2182. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-CB8, C- BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES shall be designated as Defendant No. 1259. 2183. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-OPT3 shall be designated as Defendant No. 1260. 2184. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-OPT4 shall be designated as Defendant No. 1261. 2185. Defendant CMALT (CITIMORTGAGE ALTERNATFVE LOAN TRUST), SERIES 2006-A1 shall be designated as Defendant No. 1262. 2186. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A2 shall be designated as Defendant No. 1263. 2187. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A3 shall be designated as Defendant No. 1264. 2188. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A4 shall be designated as Defendant No. 1265. - 294 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 295 of 414 PagelD #: 1061 2189. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A5 shall be designated as Defendant No. 1266. 2190. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A6 shall be designated as Defendant No. 1267. 2191. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A7 shall be designated as Defendant No. 1268. 2192. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -Al shall be designated as Defendant No. 1269. 2193. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A2 shall be designated as Defendant No. 1270. 2194. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A2 shall be designated as Defendant No. 1271. 2195. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A3 shall be designated as Defendant No. 1272. 2196. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A4 shall be designated as Defendant No. 1273. 2197. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A5 shall be designated as Defendant No. 1274. 2198. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A6 shall be designated as Defendant No. 1275. 2199. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A7 shall be designated as Defendant No. 1276. - 295 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 296 of 414 PagelD #: 1062 2200. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007 -A8 shall be designated as Defendant No. 1277. 2201. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC shall be designated as Defendant No. 1278. 2202. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC., HOMEBANC MORTGAGE TRUST 2004-2 shall be designated as Defendant No. 1279. 2203. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR4 shall be designated as Defendant No. 1280. 2204. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR6 shall be designated as Defendant No. 1281. 2205. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR7 shall be designated as Defendant No. 1282. 2206. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR8 shall be designated as Defendant No. 1283. 2207. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005- AR2 shall be designated as Defendant No. 1284. 2208. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1285. 2209. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1286. 2210. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1287. - 296 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 297 of 414 PagelD #: 1063 2211. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR3 shall be designated as Defendant No. 1288. 2212. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR5 shall be designated as Defendant No. 1289. 2213. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR6 shall be designated as Defendant No. 1290. 2214. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1291. 2215. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1292. 2216. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR8 shall be designated as Defendant No. 1293. 2217. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F1 shall be designated as Defendant No. 1294. 2218. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F2 shall be designated as Defendant No. 1295. 2219. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F3 shall be designated as Defendant No. 1296. 2220. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F3 shall be designated as Defendant No. 1297. 2221. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1298. - 297 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 298 of 414 PagelD #: 1064 2222. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006 AR1 shall be designated as Defendant No. 1299. 2223. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR1 shall be designated as Defendant No. 1300. 2224. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1301. 2225. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1302. 2226. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1303. 2227. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1304. 2228. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1305. 2229. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1306. 2230. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1307. 2231. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1308. 2232. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1309. - 298 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 299 of 414 PagelD #: 1065 2233. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1310. 2234. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR6 shall be designated as Defendant No. 1311. 2235. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1312. 2236. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR8 shall be designated as Defendant No. 1313. 2237. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007- AR1 shall be designated as Defendant No. 1314. 2238. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR2 shall be designated as Defendant No. 1315. 2239. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1316. 2240. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1317. 2241. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1318. 2242. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1319. 2243. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1320. - 299 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 300 of 414 PagelD #: 1066 2244. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1321. 2245. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1322. 2246. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1323. 2247. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR7 shall be designated as Defendant No. 1324. 2248. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST SERIES 2004-AR3 shall be designated as Defendant No. 1325. 2249. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST SERIES 2005-AR1 shall be designated as Defendant No. 1326. 2250. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1327. 2251. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1328. 2252. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1329. 2253. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1330. 2254. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1331. - 300 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 301 of 414 PagelD #: 1067 2255. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1332. 2256. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1333. 2257. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS TRUST 2003 AR3 shall be designated as Defendant No. 1334. 2258. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS TRUST 2003-AR1 shall be designated as Defendant No. 1335. 2259. Defendant SG MORTGAGE SECURITIES TRUST 2005 -OPT 1 shall be designated as Defendant No. 1336. 2260. Defendant SG MORTGAGE SECURITIES TRUST 2006-FRE1 shall be designated as Defendant No. 1337. 2261. Defendant SG MORTGAGE SECURITIES TRUST 2006-FRE2 shall be designated as Defendant No. 1338. 2262. Defendant SG MORTGAGE SECURITIES TRUST 2006-OPT2 shall be designated as Defendant No. 1339. 2263. Defendant SG MORTGAGE SECURITIES, LLC shall be designated as Defendant No. 1340. 2264. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR1 shall be designated as Defendant No. 1341. 2265. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR1 1 shall be designated as Defendant No. 1342. - 301 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 302 of 414 PagelD #: 1068 2266. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR12 shall be designated as Defendant No. 1343. 2267. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR13 shall be designated as Defendant No. 1344. 2268. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR14 shall be designated as Defendant No. 1345. 2269. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR15 shall be designated as Defendant No. 1346. 2270. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR2 shall be designated as Defendant No. 1347. 2271. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR3 shall be designated as Defendant No. 1348. 2272. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR4 shall be designated as Defendant No. 1349. 2273. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004- AR5 shall be designated as Defendant No. 1350. 2274. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR6 shall be designated as Defendant No. 1351. 2275. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR7 shall be designated as Defendant No. 1352. 2276. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR8 shall be designated as Defendant No. 1353. - 302 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 303 of 414 PagelD #: 1069 2277. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004- AR9 shall be designated as Defendant No. 1354. 2278. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 1355. 2279. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR10 shall be designated as Defendant No. 1356. 2280. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR1 1 shall be designated as Defendant No. 1357. 2281. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR12 shall be designated as Defendant No. 1358. 2282. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR13 shall be designated as Defendant No. 1359. 2283. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR14 shall be designated as Defendant No. 1360. 2284. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR15 shall be designated as Defendant No. 1361. 2285. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR16IP shall be designated as Defendant No. 1362. 2286. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR17 shall be designated as Defendant No. 1363. 2287. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR18 shall be designated as Defendant No. 1364. - 303 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 304 of 414 PagelD #: 1070 2288. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR19 shall be designated as Defendant No. 1365. 2289. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR2 shall be designated as Defendant No. 1366. 2290. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR21 shall be designated as Defendant No. 1367. 2291. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR23 shall be designated as Defendant No. 1368. 2292. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR25 shall be designated as Defendant No. 1369. 2293. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR27 shaU be designated as Defendant No. 1370. 2294. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR29 shall be designated as Defendant No. 1371. 2295. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR3 shall be designated as Defendant No. 1372. 2296. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR31 shall be designated as Defendant No. 1373. 2297. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR33 shall be designated as Defendant No. 1374. 2298. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR35 shall be designated as Defendant No. 1375. - 304 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 305 of 414 PagelD #: 1071 2299. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR4 shall be designated as Defendant No. 1376. 2300. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR5 shall be designated as Defendant No. 1377. 2301. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR6 shall be designated as Defendant No. 1378. 2302. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR7 shall be designated as Defendant No. 1379. 2303. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR8 shall be designated as Defendant No. 1380. 2304. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR9 shall be designated as Defendant No. 1381. 2305. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR1 1 shall be designated as Defendant No. 1382. 2306. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR12 shall be designated as Defendant No. 1383. 2307. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR13 shall be designated as Defendant No. 1384. 2308. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR14 shall be designated as Defendant No. 1385. 2309. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR15 shall be designated as Defendant No. 1386. - 305 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 306 of 414 PagelD #: 1072 2310. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR19 shall be designated as Defendant No. 1387. 2311. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR2 shall be designated as Defendant No. 1388. 2312. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR21 shall be designated as Defendant No. 1389. 2313. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006- AR23 shall be designated as Defendant No. 1390. 2314. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR25 shall be designated as Defendant No. 1391. 2315. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006- AR27 shaU be designated as Defendant No. 1392. 2316. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR27 shall be designated as Defendant No. 1393. 2317. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR29 shaU be designated as Defendant No. 1394. 2318. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR3 shall be designated as Defendant No. 1395. 2319. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR31 shall be designated as Defendant No. 1396. 2320. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR33 shall be designated as Defendant No. 1397. - 306 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 307 of 414 PagelD #: 1073 2321. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR35 shall be designated as Defendant No. 1398. 2322. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR37 shall be designated as Defendant No. 1399. 2323. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR39 shall be designated as Defendant No. 1400. 2324. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR4 shall be designated as Defendant No. 1401. 2325. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR41 shall be designated as Defendant No. 1402. 2326. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR5 shall be designated as Defendant No. 1403. 2327. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR6 shall be designated as Defendant No. 1404. 2328. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR7 shall be designated as Defendant No. 1405. 2329. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR8 shall be designated as Defendant No. 1406. 2330. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR9 shall be designated as Defendant No. 1407. 2331. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-FLX1 shall be designated as Defendant No. 1408. - 307 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 308 of 414 PagelD #: 1074 2332. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-R1 shall be designated as Defendant No. 1409. 2333. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR1 shall be designated as Defendant No. 1410. 2334. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR1 1 shall be designated as Defendant No. 1411. 2335. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR13 shall be designated as Defendant No. 1412. 2336. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR15 shall be designated as Defendant No. 1413. 2337. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR17 shall be designated as Defendant No. 1414. 2338. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR19 shall be designated as Defendant No. 1415. 2339. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007 -AR2 IIP shall be designated as Defendant No. 1416. 2340. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007 -AR5 shall be designated as Defendant No. 1417. 2341. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007 -AR7 shall be designated as Defendant No. 1418. 2342. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007 -AR9 shall be designated as Defendant No. 1419. - 308 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 309 of 414 PagelD #: 1075 2343. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007 -FLX1 shall be designated as Defendant No. 1420. 2344. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX2 shall be designated as Defendant No. 1421. 2345. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX2 shall be designated as Defendant No. 1422. 2346. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX3 shall be designated as Defendant No. 1423. 2347. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX4 shall be designated as Defendant No. 1424. 2348. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX5 shall be designated as Defendant No. 1425. 2349. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX6 shaU be designated as Defendant No. 1426. 2350. Defendant GMAC MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- AR1 shall be designated as Defendant No. 1427. 2351. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1428. 2352. Defendant GMACM HOME EQUITY LOAN BACKED NOTES SERIES 2002- HE4 shall be designated as Defendant No. 1429. 2353. Defendant GMACM HOME EQUITY LOAN BACKED TERM NOTES SER 2003-HE1 shall be designated as Defendant No. 1430. - 309 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 310 of 414 PagelD #: 1076 2354. Defendant GMACM HOME EQUITY LOAN BACKED TERM NOTES SERIES 2000-HE4 shall be designated as Defendant No. 1431. 2355. Defendant GMACM HOME EQUITY LOAN TRUST 2003-HE2 shall be designated as Defendant No. 1432. 2356. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE3 shall be designated as Defendant No. 1433. 2357. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE4 shall be designated as Defendant No. 1434. 2358. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE5 shall be designated as Defendant No. 1435. 2359. Defendant GMACM HOME EQUITY LOAN TRUST 2005 -HE 1 shall be designated as Defendant No. 1436. 2360. Defendant GMACM HOME EQUITY LOAN TRUST 2005 -HE2 shall be designated as Defendant No. 1437. 2361. Defendant GMACM HOME EQUITY LOAN TRUST 2005 -HE3 shall be designated as Defendant No. 1438. 2362. Defendant GMACM HOME EQUITY LOAN TRUST 2006-HE5 shall be designated as Defendant No. 1439. 2363. Defendant GMACM HOME EQUITY LOAN-BACKED NOTES SERIES 2001- HE1 shall be designated as Defendant No. 1440. 2364. Defendant GMACM HOME EQUITY LOAN-BACKED TERM NOTES SERIES 2001-HE2 shall be designated as Defendant No. 1441. - 310 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 311 of 414 PagelD #: 1077 2365. Defendant GMACM HOME EQUITY LOAN-BACKED TERM NOTES SERIES 2001 -HE3 shall be designated as Defendant No. 1442. 2366. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2000- CL1 shall be designated as Defendant No. 1443. 2367. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2000- HLTV2 shall be designated as Defendant No. 1444. 2368. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2002- HLTV1 shall be designated as Defendant No. 1445. 2369. Defendant GMACM HOME LOAN TRUST 2004-HLTV1 shall be designated as Defendant No. 1446. 2370. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- CL1 shall be designated as Defendant No. 1447. 2371. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- HLTV1 shall be designated as Defendant No. 1448. 2372. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- HLTV2 shall be designated as Defendant No. 1449. 2373. Defendant GMACM MORTGAGE LOAN BACKED NOTES SERIES 2000- HE3 shall be designated as Defendant No. 1450. 2374. Defendant GMACM MORTGAGE LOAN TRUST 2003-J7 shall be designated as Defendant No. 1451. 2375. Defendant GMACM MORTGAGE LOAN TRUST 2004-GH1 shall be designated as Defendant No. 1452. - 311 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 312 of 414 PagelD #: 1078 2376. Defendant GMACM MORTGAGE LOAN TRUST 2005-AA1 shall be designated as Defendant No. 1453. 2377. Defendant GMACM MORTGAGE LOAN TRUST 2005-AF1 shall be designated as Defendant No. 1454. 2378. Defendant GMACM MORTGAGE LOAN TRUST 2005-AF2 shall be designated as Defendant No. 1455. 2379. Defendant GMACM MORTGAGE LOAN TRUST 2005 -AR1 shall be designated as Defendant No. 1456. 2380. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 1457. 2381. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR2 shall be designated as Defendant No. 1458. 2382. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR3 shall be designated as Defendant No. 1459. 2383. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR4 shall be designated as Defendant No. 1460. 2384. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR5 shall be designated as Defendant No. 1461. 2385. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR6 shall be designated as Defendant No. 1462. 2386. Defendant GMACM MORTGAGE LOAN TRUST 2005-J1 shall be designated as Defendant No. 1463. - 312 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 313 of 414 PagelD #: 1079 2387. Defendant GMACM MORTGAGE PASS THRU CERTS SERIES 2003-J8 shall be designated as Defendant No. 1464. 2388. Defendant GMACM MORTGAGE PASS-THROUGH CERIFICATES, SERIES 2004- J5 shall be designated as Defendant No. 1465. 2389. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2003- J5 shall be designated as Defendant No. 1466. 2390. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR2 shall be designated as Defendant No. 1467. 2391. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J2 shall be designated as Defendant No. 1468. 2392. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J3 shall be designated as Defendant No. 1469. 2393. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J4 shall be designated as Defendant No. 1470. 2394. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J6 shall be designated as Defendant No. 1471. 2395. Defendant RAAC SERIES 2004-SP1 TRUST shall be designated as Defendant No. 1472. 2396. Defendant RAAC SERIES 2004-SP2 shall be designated as Defendant No. 1473. 2397. Defendant RAAC SERIES 2004-SP3 shall be designated as Defendant No. 1474. 2398. Defendant RAAC SERIES 2005-SP1 TRUST shall be designated as Defendant No. 1475. - 313 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 314 of 414 PagelD #: 1080 2399. Defendant RAAC SERIES 2005-SP3 TRUST shall be designated as Defendant No. 1476. 2400. Defendant RAAC SERIES 2007 SP2 TRUST shall be designated as Defendant No. 1477. 2401. Defendant RAAC SERIES 2007-SP1 TRUST shall be designated as Defendant No. 1478. 2402. Defendant RAAC SERIES 2007-SP3 TRUST shall be designated as Defendant No. 1479. 2403. Defendant RAAC SERIES 2007-SP3 TRUST shall be designated as Defendant No. 1480. 2404. Defendant RAMP SERIES 2004-R12 TRUST shall be designated as Defendant No. 1481. 2405. Defendant RAMP SERIES 2004-RS1 TRUST shall be designated as Defendant No. 1482. 2406. Defendant RAMP SERIES 2004-RS1 TRUST shall be designated as Defendant No. 1483. 2407. Defendant RAMP SERIES 2004-RS10 TRUST shall be designated as Defendant No. 1484. 2408. Defendant RAMP SERIES 2004-RS11 TRUST shall be designated as Defendant No. 1485. 2409. Defendant RAMP SERIES 2004-RS2 TRUST shall be designated as Defendant No. 1486. - 314 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 315 of 414 PagelD #: 1081 2410. Defendant RAMP SERIES 2004-RS4 TRUST shall be designated as Defendant No. 1487. 2411. Defendant RAMP SERIES 2004-RS5 TRUS shall be designated as Defendant No. 1488. 2412. Defendant RAMP SERIES 2004-RS6 TRUST shall be designated as Defendant No. 1489. 2413. Defendant RAMP SERIES 2004-RS7 TRUST shall be designated as Defendant No. 1490. 2414. Defendant RAMP SERIES 2004-RS8 TRUST shall be designated as Defendant No. 1491. 2415. Defendant RAMP SERIES 2004-RS9 TRUST shall be designated as Defendant No. 1492. 2416. Defendant RAMP SERIES 2004-RZ2 TRUST shall be designated as Defendant No. 1493. 2417. Defendant RAMP SERIES 2004-RZ3 TRUST shall be designated as Defendant No. 1494. 2418. Defendant RAMP SERIES 2004-RZ3 TRUST shall be designated as Defendant No. 1495. 2419. Defendant RAMP SERIES 2004-RZ4 TRUST shall be designated as Defendant No. 1496. 2420. Defendant RAMP SERIES 2004-SL2 TRUST shall be designated as Defendant No. 1497. - 315 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 316 of 414 PagelD #: 1082 2421. Defendant RAMP SERIES 2004-SL3 TRUST shall be designated as Defendant No. 1498. 2422. Defendant RAMP SERIES 2004-SL4 TRUST shall be designated as Defendant No. 1499. 2423. Defendant RAMP SERIES 2005 SL2 TRUST shall be designated as Defendant No. 1500. 2424. Defendant RAMP SERIES 2005 -EFC1 TRUST shall be designated as Defendant No. 1501. 2425. Defendant RAMP SERIES 2005-EFC2 shall be designated as Defendant No. 1502. 2426. Defendant RAMP SERIES 2005-EFC3 TRUST shall be designated as Defendant No. 1503. 2427. Defendant RAMP SERIES 2005-EFC4 TRUST shall be designated as Defendant No. 1504. 2428. Defendant RAMP SERIES 2005-EFC5 TRUST shall be designated as Defendant No. 1505. 2429. Defendant RAMP SERIES 2005-EFC6 TRUST shall be designated as Defendant No. 1506. 2430. Defendant RAMP SERIES 2005-RS2 TRUST shall be designated as Defendant No. 1507. 2431. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1508. - 316 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 317 of 414 PagelD #: 1083 2432. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1509. 2433. Defendant RAMP SERIES 2005-RS4 TRUST shall be designated as Defendant No. 1510. 2434. Defendant RAMP SERIES 2005-RS5 TRUST shall be designated as Defendant No. 1511. 2435. Defendant RAMP SERIES 2005-RS6 TRUST shall be designated as Defendant No. 1512. 2436. Defendant RAMP SERIES 2005-RS7 TRUST shall be designated as Defendant No. 1513. 2437. Defendant RAMP SERIES 2005-RS8 TRUST shall be designated as Defendant No. 1514. 2438. Defendant RAMP SERIES 2005-RS9 TRUST shall be designated as Defendant No. 1515. 2439. Defendant RAMP SERIES 2005-RZ1 TRUST shall be designated as Defendant No. 1516. 2440. Defendant RAMP SERIES 2005-RZ2 TRUST shall be designated as Defendant No. 1517. 2441. Defendant RAMP SERIES 2005-RZ3 TRUST shall be designated as Defendant No. 1518. 2442. Defendant RAMP SERIES 2005-RZ4 TRUST shall be designated as Defendant No. 1519. - 317 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 318 of 414 PagelD #: 1084 2443. Defendant RAMP SERIES 2005-SL1 TRUST shall be designated as Defendant No. 1520. 2444. Defendant RAMP SERIES 2005 -SP2 TRUST shall be designated as Defendant No. 1521. 2445. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1522. 2446. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1523. 2447. Defendant RAMP SERIES 2006-SP1 TRUST shall be designated as Defendant No. 1524. 2448. Defendant RESIDENTIAL ASSET BACKED PASS THR CERTS SER 2003- RS4 shall be designated as Defendant No. 1525. 2449. Defendant RESIDENTIAL ASSET GMACM MORTGAGE LOAN TRUST 2004- JR1 shall be designated as Defendant No. 1526. 2450. Defendant RESIDENTIAL ASSET MOR PRO INC GMACM MO PASS TH CE SE 2006 J6 shall be designated as Defendant No. 1527. 2451. Defendant RESIDENTIAL ASSET MORT PRO INC GMACM MO PA TH CE SE 03 AR2 shall be designated as Defendant No. 1528. 2452. Defendant RESIDENTIAL ASSET MORT PROD GMACM PS THR CERTS SER 2003-J4 shall be designated as Defendant No. 1529. 2453. Defendant RESIDENTIAL ASSET MORT PROD INC GMACH HM EQ LN TR 2002-HE1 shall be designated as Defendant No. 1530. - 318 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 319 of 414 PagelD #: 1085 2454. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ L N TR 04 HE2 shall be designated as Defendant No. 1531. 2455. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE1 shall be designated as Defendant No. 1532. 2456. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE2 shall be designated as Defendant No. 1533. 2457. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1534. 2458. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1535. 2459. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2004 HE1 shall be designated as Defendant No. 1536. 2460. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM MORT LN TR 03-J2 shall be designated as Defendant No. 1537. 2461. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 RZ1 TRUST shall be designated as Defendant No. 1538. 2462. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 SL1 TRUST shall be designated as Defendant No. 1539. 2463. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LN TR 03 GH2 shall be designated as Defendant No. 1540. 2464. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LOAN TR 03 J10 shall be designated as Defendant No. 1541. - 319 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 320 of 414 PagelD #: 1086 2465. Defendant RESIDENTIAL ASSET MORT PRODUCT GMACM LOAN SER 2003-AR1 shall be designated as Defendant No. 1542. 2466. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03 J3 shall be designated as Defendant No. 1543. 2467. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03-J1 shall be designated as Defendant No. 1544. 2468. Defendant RESIDENTIAL ASSET MORTGAGE PROD INC GMACM MOR LN TR 2003-GH1 shall be designated as Defendant No. 1545. 2469. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS GMACM TRUST 2004-J1 shall be designated as Defendant No. 1546. 2470. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1547. 2471. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1548. 2472. Defendant RAMP SERIES 2005-RS4 TRUST shall be designated as Defendant No. 1549. 2473. Defendant RAMP SERIES 2005-RS5 TRUST shall be designated as Defendant No. 1550. 2474. Defendant RAMP SERIES 2005-RS6 TRUST shall be designated as Defendant No. 1551. 2475. Defendant RAMP SERIES 2005-RS7 TRUST shall be designated as Defendant No. 1552. - 320 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 321 of 414 PagelD #: 1087 2476. Defendant RAMP SERIES 2005-RS8 TRUST shall be designated as Defendant No. 1553. 2477. Defendant RAMP SERIES 2005-RS9 TRUST shall be designated as Defendant No. 1554. 2478. Defendant RAMP SERIES 2005-RZ1 TRUST shall be designated as Defendant No. 1555. 2479. Defendant RAMP SERIES 2005-RZ2 TRUST shall be designated as Defendant No. 1556. 2480. Defendant RAMP SERIES 2005-RZ3 TRUST shall be designated as Defendant No. 1557. 2481. Defendant RAMP SERIES 2005-RZ4 TRUST shall be designated as Defendant No. 1558. 2482. Defendant RAMP SERIES 2005-SL1 TRUST shall be designated as Defendant No. 1559. 2483. Defendant RAMP SERIES 2005 -SP2 TRUST shall be designated as Defendant No. 1560. 2484. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1561. 2485. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1562. 2486. Defendant RAMP SERIES 2006-SP1 TRUST shall be designated as Defendant No. 1563. - 321 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 322 of 414 PagelD #: 1088 2487. Defendant RESIDENTIAL ASSET BACKED PASS THR CERTS SER 2003- RS4 shall be designated as Defendant No. 1564. 2488. Defendant RESIDENTIAL ASSET GMACM MORTGAGE LOAN TRUST 2004- JR1 shall be designated as Defendant No. 1565. 2489. Defendant RESIDENTIAL ASSET MOR PRO INC GMACM MO PASS TH CE SE 2006 J6 shall be designated as Defendant No. 1566. 2490. Defendant RESIDENTIAL ASSET MORT PRO INC GMACM MO PA TH CE SE 03 AR2 shall be designated as Defendant No. 1567. 2491. Defendant RESIDENTIAL ASSET MORT PROD GMACM PS THR CERTS SER 2003-J4 shall be designated as Defendant No. 1568. 2492. Defendant RESIDENTIAL ASSET MORT PROD INC GMACH HM EQ LN TR 2002-HE1 shall be designated as Defendant No. 1569. 2493. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ L N TR 04 HE2 shall be designated as Defendant No. 1570. 2494. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE1 shall be designated as Defendant No. 1571. 2495. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE2 shall be designated as Defendant No. 1572. 2496. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1573. 2497. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1574. - 322 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 323 of 414 PagelD #: 1089 2498. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2004 HE1 shall be designated as Defendant No. 1575. 2499. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM MORT LN TR 03-J2 shall be designated as Defendant No. 1576. 2500. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 RZ1 TRUST shall be designated as Defendant No. 1577. 2501. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 SL1 TRUST shall be designated as Defendant No. 1578. 2502. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LN TR 03 GH2 shall be designated as Defendant No. 1579. 2503. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LOAN TR 03 J10 shall be designated as Defendant No. 1580. 2504. Defendant RESIDENTIAL ASSET MORT PRODUCT GMACM LOAN SER 2003-AR1 shall be designated as Defendant No. 1581. 2505. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03 J3 shall be designated as Defendant No. 1582. 2506. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03-J1 shall be designated as Defendant No. 1583. 2507. Defendant RESIDENTIAL ASSET MORTGAGE PROD INC GMACM MOR LN TR 2003-GH1 shall be designated as Defendant No. 1584. 2508. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS GMACM TRUST 2004-J1 shall be designated as Defendant No. 1585. - 323 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 324 of 414 PagelD #: 1090 2509. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1586. 2510. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC TRUST 2000-HLTV1 shall be designated as Defendant No. 1587. 2511. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS RAMP TRUST 2004-RS3 shall be designated as Defendant No. 1588. 2512. Defendant RESIDENTIAL ASST MORT PROD GMACM MT PS THR CERTS SER 2003-J9 shall be designated as Defendant No. 1589. 2513. Defendant DEUTSCHE ALT- A SECURITIES MORTGAGE LOAN TRUST SERIES 2007-2 shall be designated as Defendant No. 1590. 2514. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST SERIES 2007-OA5 /DE shall be designated as Defendant No. 1591. 2515. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AF1 shall be designated as Defendant No. 1592. 2516. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR2 shall be designated as Defendant No. 1593. 2517. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR3 shall be designated as Defendant No. 1594. 2518. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR4 shall be designated as Defendant No. 1595. 2519. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR5 shall be designated as Defendant No. 1596. - 324 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 325 of 414 PagelD #: 1091 2520. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR6 shall be designated as Defendant No. 1597. 2521. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-OA1 shall be designated as Defendant No. 1598. 2522. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-1 shall be designated as Defendant No. 1599. 2523. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-1 shall be designated as Defendant No. 1600. 2524. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-3 shall be designated as Defendant No. 1601. 2525. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007 -AR1 shall be designated as Defendant No. 1602. 2526. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007 -AR2 shall be designated as Defendant No. 1603. 2527. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007 -AR2 shall be designated as Defendant No. 1604. 2528. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007 -AR3 shall be designated as Defendant No. 1605. 2529. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA1 shall be designated as Defendant No. 1606. 2530. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA2 shall be designated as Defendant No. 1607. - 325 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 326 of 414 PagelD #: 1092 2531. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA3 /DE shall be designated as Defendant No. 1608. 2532. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA4 /DE shall be designated as Defendant No. 1609. 2533. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-RAMP1 shall be designated as Defendant No. 1610. 2534. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-1 shall be designated as Defendant No. 1611. 2535. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-2 shall be designated as Defendant No. 1612. 2536. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-3 shall be designated as Defendant No. 1613. 2537. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-4 shall be designated as Defendant No. 1614. 2538. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-5 shall be designated as Defendant No. 1615. 2539. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-6 shall be designated as Defendant No. 1616. 2540. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1617. 2541. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1618. - 326 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 327 of 414 PagelD #: 1093 2542. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1619. 2543. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005- AR2 shall be designated as Defendant No. 1620. 2544. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2006-AR1 shall be designated as Defendant No. 1621. 2545. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AB1 shall be designated as Defendant No. 1622. 2546. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AB3 shall be designated as Defendant No. 1623. 2547. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2007 -AB1 shall be designated as Defendant No. 1624. 2548. Defendant DEUTSCHE ALT-B SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2006- AB2 shall be designated as Defendant No. 1625. 2549. Defendant DEUTSHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1626. 2550. Defendant MORTGAGE LOAN TRUST SERIES 2003-2XS shall be designated as Defendant No. 1627. 255 1 . Defendant SASCO MORTGAGE LOAN TRUST 2004-GEL3 shall be designated as Defendant No. 1628. 2552. Defendant SASCO MORTGAGE LOAN TRUST 2005-WF3 shall be designated as Defendant No. 1629. - 327 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 328 of 414 PagelD #: 1094 2553. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2003-GEL1 shall be designated as Defendant No. 1630. 2554. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2004-GEL2 shall be designated as Defendant No. 1631. 2555. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL1 shall be designated as Defendant No. 1632. 2556. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL2 shall be designated as Defendant No. 1633. 2557. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL3 shall be designated as Defendant No. 1634. 2558. Defendant SASCO MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2005-NC1 shall be designated as Defendant No. 1635. 2559. Defendant SASCO MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2005-NC2 shall be designated as Defendant No. 1636. 2560. Defendant SASCO MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- S4 shall be designated as Defendant No. 1637. 2561. Defendant SASCO MORTGAGE PASS-THROUGH CERTIFIDATES, SERIES 2005- WMC1 shall be designated as Defendant No. 1638. 2562. Defendant STRUCT ASS MORT INV INC BS ALTA MORT PAS THR CER SER 2003 1 shall be designated as Defendant No. 1639. 2563. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE shall be designated as Defendant No. 1640. - 328 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 329 of 414 PagelD #: 1095 2564. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN RATE shall be designated as Defendant No. 1641. 2565. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1642. 2566. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1643. 2567. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1644. 2568. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1645. 2569. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1646. 2570. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1647. 2571. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1648. 2572. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1649. 2573. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1650. 2574. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1651. - 329 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 330 of 414 PagelD #: 1096 2575. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1652. 2576. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1653. 2577. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2004- 5 shall be designated as Defendant No. 1654. 2578. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005- 3XS shall be designated as Defendant No. 1655. 2579. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005-6XS shall be designated as Defendant No. 1656. 2580. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005-8XS shall be designated as Defendant No. 1657. 2581. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-14 shall be designated as Defendant No. 1658. 2582. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-15 shall be designated as Defendant No. 1659. 2583. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-16 shall be designated as Defendant No. 1660. - 330 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 331 of 414 PagelD #: 1097 2584. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-17 shall be designated as Defendant No. 1661. 2585. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-12 shall be designated as Defendant No. 1662. 2586. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-15 shall be designated as Defendant No. 1663. 2587. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-16XS shall be designated as Defendant No. 1664. 2588. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-17 shall be designated as Defendant No. 1665. 2589. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-18 shall be designated as Defendant No. 1666. 2590. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-2 shall be designated as Defendant No. 1667. 2591. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-20 shall be designated as Defendant No. 1668. 2592. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-20 shall be designated as Defendant No. 1669. 2593. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-21 shall be designated as Defendant No. 1670. 2594. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-22 shall be designated as Defendant No. 1671. - 331 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 332 of 414 PagelD #: 1098 2595. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-23 shall be designated as Defendant No. 1672. 2596. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-4 shall be designated as Defendant No. 1673. 2597. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-7 shall be designated as Defendant No. 1674. 2598. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-7N shall be designated as Defendant No. 1675. 2599. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-1 shall be designated as Defendant No. 1676. 2600. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-10 shall be designated as Defendant No. 1677. 2601. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-1 1 shall be designated as Defendant No. 1678. 2602. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-12 shall be designated as Defendant No. 1679. 2603. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-2 shall be designated as Defendant No. 1680. 2604. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-3 shall be designated as Defendant No. 1681. 2605. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-4 shall be designated as Defendant No. 1682. - 332 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 333 of 414 PagelD #: 1099 2606. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-5 shall be designated as Defendant No. 1683. 2607. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-6 shall be designated as Defendant No. 1684. 2608. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-7 shall be designated as Defendant No. 1685. 2609. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-8 shall be designated as Defendant No. 1686. 2610. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-9 shall be designated as Defendant No. 1687. 261 1. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-1 shall be designated as Defendant No. 1688. 2612. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-10 shall be designated as Defendant No. 1689. 2613. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-1 1 shall be designated as Defendant No. 1690. 2614. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-2 shall be designated as Defendant No. 1691. 2615. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-3 shall be designated as Defendant No. 1692. 2616. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-4 shall be designated as Defendant No. 1693. - 333 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 334 of 414 PagelD #: 1100 2617. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-5 shall be designated as Defendant No. 1694. 2618. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-6 shall be designated as Defendant No. 1695. 2619. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-7 shall be designated as Defendant No. 1696. 2620. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-8 shall be designated as Defendant No. 1697. 2621. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-9 shall be designated as Defendant No. 1698. 2622. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2008-1 shall be designated as Defendant No. 1699. 2623. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2008-2 shall be designated as Defendant No. 1700. 2624. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 1 shall be designated as Defendant No. 1701. 2625. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 10 shall be designated as Defendant No. 1702. 2626. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 1 1 shall be designated as Defendant No. 1703. 2627. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 3 shall be designated as Defendant No. 1704. - 334 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 335 of 414 PagelD #: 1101 2628. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 5 shall be designated as Defendant No. 1705. 2629. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 6 shall be designated as Defendant No. 1706. 2630. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 7 shall be designated as Defendant No. 1707. 2631. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 8 shall be designated as Defendant No. 1708. 2632. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 9 shall be designated as Defendant No. 1709. 2633. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 05 2 shall be designated as Defendant No. 1710. 2634. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 05 3 shall be designated as Defendant No. 171 1. 2635. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TR 2004 1 shall be designated as Defendant No. 1712. 2636. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TR 2004 2 shall be designated as Defendant No. 1713. 2637. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TRUST 03-7 shall be designated as Defendant No. 1714. 2638. Defendant STRUCTURED ASSET MORT INV II INC MORT PAS THR CERT SE 04 CL1 shall be designated as Defendant No. 1715. - 335 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 336 of 414 PagelD #: 1102 2639. Defendant STRUCTURED ASSET MORT INV II INC PRIME MORTGAGE TRUST 2003 2 shall be designated as Defendant No. 1716. 2640. Defendant STRUCTURED ASSET MORT INV II INC THORNBURG MORT SEC TR 03 5 shall be designated as Defendant No. 1717. 2641. Defendant STRUCTURED ASSET MORT INV INC BEAR STEARNS ALT A TR 03 4 shall be designated as Defendant No. 1718. 2642. Defendant STRUCTURED ASSET MORT INV INC BEAR STEARNS ARM TRUST 2003 3 shall be designated as Defendant No. 1719. 2643. Defendant STRUCTURED ASSET MORT INV INC MORT BACK NTS SER 2003-1 shall be designated as Defendant No. 1720. 2644. Defendant STRUCTURED ASSET MORT INV INC MORT PAS THR CERTS SER 2003-3 shall be designated as Defendant No. 1721. 2645. Defendant STRUCTURED ASSET MORT INV INC MORT PASS THR CERTS SER 2003-1 shall be designated as Defendant No. 1722. 2646. Defendant STRUCTURED ASSET MORT INV INC THORNBURG MORT SEC TR 2003-2 shall be designated as Defendant No. 1723. 2647. Defendant STRUCTURED ASSET MORT INVEST INC MORT PAS THR CERT SE 03 CL1 shall be designated as Defendant No. 1724. 2648. Defendant STRUCTURED ASSET MORT INVEST INC MORT PAS THR CERTS SER 03 1 shall be designated as Defendant No. 1725. 2649. Defendant STRUCTURED ASSET MORT INVESTMENT THORNBURG SEC TRUST 2004-1 shall be designated as Defendant No. 1726. - 336 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 337 of 414 PagelD #: 1103 2650. Defendant STRUCTURED ASSET MORT PASS THRU CERTS SERIES 2003 AR4 shall be designated as Defendant No. 1727. 2651. Defendant STRUCTURED ASSET MORT PASS THRU CERTS SERIES 2004 AR3 shall be designated as Defendant No. 1728. 2652. Defendant STRUCTURED ASSET MORTGAGE INVEST TRUST 2003-AR2 shall be designated as Defendant No. 1729. 2653. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II 2005-AR4 shall be designated as Defendant No. 1730. 2654. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC shall be designated as Defendant No. 1731. 2655. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC., HOMEBANC MORTGAGE TRUST 2004-2 shall be designated as Defendant No. 1732. 2656. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II SERIES 2004- AR5 shall be designated as Defendant No. 1733. 2657. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR4 shall be designated as Defendant No. 1734. 2658. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR6 shall be designated as Defendant No. 1735. 2659. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR7 shall be designated as Defendant No. 1736. 2660. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR8 shall be designated as Defendant No. 1737. - 337 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 338 of 414 PagelD #: 1104 2661. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1738. 2662. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1739. 2663. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1740. 2664. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR3 shall be designated as Defendant No. 1741. 2665. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR5 shall be designated as Defendant No. 1742. 2666. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR6 shall be designated as Defendant No. 1743. 2667. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1744. 2668. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1745. 2669. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR8 shall be designated as Defendant No. 1746. 2670. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F1 shall be designated as Defendant No. 1747. 2671. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F2 shall be designated as Defendant No. 1748. - 338 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 339 of 414 PagelD #: 1105 2672. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F3 shall be designated as Defendant No. 1749. 2673. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005- F3 shall be designated as Defendant No. 1750. 2674. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR1 shall be designated as Defendant No. 1751. 2675. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1752. 2676. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1753. 2677. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1754. 2678. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1755. 2679. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1756. 2680. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1757. 2681. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1758. 2682. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1759. - 339 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 340 of 414 PagelD #: 1106 2683. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1760. 2684. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1761. 2685. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR6 shall be designated as Defendant No. 1762. 2686. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1763. 2687. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1764. 2688. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR8 shall be designated as Defendant No. 1765. 2689. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1766. 2690. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006 AR1 shall be designated as Defendant No. 1767. 2691. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007- AR1 shall be designated as Defendant No. 1768. 2692. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR2 shall be designated as Defendant No. 1769. 2693. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1770. - 340 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 341 of 414 PagelD #: 1107 2694. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1771. 2695. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1772. 2696. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1773. 2697. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1774. 2698. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1775. 2699. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1776. 2700. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1777. 2701. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR7 shall be designated as Defendant No. 1778. 2702. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2006-BC5 shall be designated as Defendant No. 1779. 2703. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2006-BC6 shall be designated as Defendant No. 1780. 2704. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC2 shall be designated as Defendant No. 1781. - 341 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 342 of 414 PagelD #: 1108 2705. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC3 shall be designated as Defendant No. 1782. 2706. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC4 shall be designated as Defendant No. 1783. 2707. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-OSI shall be designated as Defendant No. 1784. 2708. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-WF1 shall be designated as Defendant No. 1785. 2709. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-WF2 shall be designated as Defendant No. 1786. 2710. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004- 11XS shall be designated as Defendant No. 1787. 2711. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004-9XS shall be designated as Defendant No. 1788. 2712. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004-S2 shall be designated as Defendant No. 1789. 2713. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-10 shall be designated as Defendant No. 1790. 2714. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-13 shall be designated as Defendant No. 1791. - 342 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 343 of 414 PagelD #: 1109 2715. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-15 shall be designated as Defendant No. 1792. 2716. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004- 16XS shall be designated as Defendant No. 1793. 2717. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-17XS shall be designated as Defendant No. 1794. 2718. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-19-XS shall be designated as Defendant No. 1795. 2719. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-20 shall be designated as Defendant No. 1796. 2720. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-2 1XS shall be designated as Defendant No. 1797. 2721. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-22 shall be designated as Defendant No. 1798. - 343 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 344 of 414 PagelD #: 1110 2722. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-23XS shall be designated as Defendant No. 1799. 2723. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-7 shall be designated as Defendant No. 1800. 2724. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-1 shall be designated as Defendant No. 1801. 2725. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-10 shall be designated as Defendant No. 1802. 2726. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-1 1H shall be designated as Defendant No. 1803. 2727. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-2XS shall be designated as Defendant No. 1804. 2728. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1805. - 344 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 345 of 414 PagelD #: 1111 2729. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1806. 2730. Defendant STRUCTURED ASSET SECURITIES CORP. MORTGAGE LOAN TRUST 2005-7XS shall be designated as Defendant No. 1807. 2731. Defendant STRUCTURES ASSET MORT PRIME MORT TR PAS THR CER SER 2004 CL2 shall be designated as Defendant No. 1808. 2732. Defendant CITIFINANCIAL PROMOTORA DE NEGOCIOS & COBRANCA LTDA. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1809.) 2733. Defendant CITIBANK CORRETORA DE SEGUROS LTDA. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1810.) 2734. Defendant BANCO CITICARD S.A. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1811.) 2735. Defendant BANK HANDLOWY W WARSZAWIE S.A. is an Unknown Business Entity located in Poland. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1812.) - 345 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 346 of 414 PagelD #: 1112 2736. Defendant CITI OVERSEAS INVESTMENTS BAHAMAS, INC. is a Corporation located in Bahamas. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1813.) 2737. Defendant CITIBANK CARTOES PARTICIPACOES LTD A. is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1814.) 2738. Defendant CITIGROUP GLOBAL MARKETS CORPORATION & CO. BESCHRANKT HAFTENDE KG is a Corporation located in Germany. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1815.) 2739. Defendant CITIGROUP GLOBAL MARKETS DEUTSCHLAND AG is a Corporation located in Germany. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1816.) 2740. Defendant CITIBANK MEDIADOR, OPERADOR DE BANCA - SEGUROS VTNCULADO, SOCIEDAD ANONIMA is an Unknown Business Entity located in Spain. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1817.) 2741. Defendant CITIBANK HOLDINGS IRELAND LIMITED is an Unknown Business Entity located in Ireland. This Defendant is fully subject to jurisdiction in - 346 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 347 of 414 PagelD #: 1113 this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1818.) 2742. Defendant CITICORP CAPITAL PHILIPPINES, INC. is a Corporation located in Philippines. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1819.) 2743. Defendant CITICORP FINANCE (INDIA) LIMITED is an Unknown Business Entity located in India. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1820.) 2744. Defendant CITIGROUP ASIA PACIFIC HOLDING CORPORATION is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1821.) 2745. Defendant CITIGROUP HOLDING (SINGAPORE) PRIVATE LIMITED is an Unknown Business Entity located in Singapore. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1822.) 2746. Defendant CITIBANK (HONG KONG) LIMITED is an Unknown Business Entity located in Hong Kong. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1823.) - 347 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 348 of 414 PagelD #: 1114 2747. Defendant CITIBANK BERHAD is an Unknown Business Entity located in Malaysia. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1824.) 2748. Defendant CITIBANK MALAYSIA (L) LIMITED is an Unknown Business Entity located in Malaysia. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1825.) 2749. Defendant CITIGROUP NETHERLANDS HOLDINGS B.V. is a Limited Liability Company located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1826.) 2750. Defendant LATIN AMERICAN INVESTMENT BANK BAHAMAS LIMITED is an Unknown Business Entity located in Bahamas. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1827.) 2751. Defendant ZAO CITIBANK is an Unknown Business Entity located in Russian Federation. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1828.) 2752. Defendant CITIGROUP GLOBAL MARKETS LUXEMBOURG is an Unknown Business Entity located in Luxembourg. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1829.) - 348 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 349 of 414 PagelD #: 1115 2753. Defendant CITIGROUP GLOBAL MARKETS HONG KONG HOLDINGS LIMITED is an Unknown Business Entity located in Hong Kong. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No 1830.) 2754. Defendant CITIGROUP GLOBAL MARKETS SINGAPORE HOLDINGS PTE. LTD. is an Unknown Business Entity located in Singapore. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1831.) 2755. Defendant CITIGROUP GLOBAL MARKETS, SINGAPORE PTE. LTD. is an Unknown Business Entity located in Singapore. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1832.) 2756. Defendant CITIGROUP GLOBAL MARKETS INDIA PRIVATE LIMITED is an Unknown Business Entity located in India. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1833.) 2757. Defendant CITIGROUP GLOBAL MARKETS COMMERCIAL CORP. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1834.) 2758. Defendant COHM OVERSEAS MEXICO HOLDING, S. DE R.L. DE C.V. is a Limited Liability Company located in Mexico. This Defendant is fully subject to - 349 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 350 of 414 PagelD #: 1116 jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1835.) 2759. Defendant ELAVON DO BRASIL SOLUCOES DE PAGAMENTO S.A is an Unknown Business Entity located in Brazil. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1836.) 2760. Defendant ELAVON EUROPEAN HOLDINGS, C.V. is a Limited Partnership located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1837.) 2761. Defendant ELAVON FINANCIAL SERVICES LIMITED is an Unknown Business Entity located in Ireland. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1838.) 2762. Defendant USB NETHERLANDS B.V. is a Private Limited Liability Company located in Netherlands. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1839.) 2763. Defendant USB REALTY CORP. is a Corporation located in Delaware. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1840.) 2764. Defendant USB TRADE SERVICES LIMITED is an Unknown Business Entity located in Hong Kong. This Defendant is fully subject to jurisdiction in this action - 350 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 351 of 414 PagelD #: 1117 pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1841.) 2765. Defendant ELAVON MERCHANT SERVICES MEXICO, S. DE R.L. DE C.V. is a Limited Liability Company located in Mexico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1842.) 2766. Defendant ELAVON MEXICO HOLDING COMPANY, S.A. DE C.V. is a Corporation located in Mexico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1843.) 2767. Defendant ELAVON OPERATIONS COMPANY, S. DE R.I. DE C.V. is an Unknown Business Entity located in Mexico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1844.) 2768. Defendant ELAVON PUERTO RICO, INC. is a Corporation located in Puerto Rico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1845.) 2769. Defendant ELAVON SERVICES COMPANY, S. DE R.I. DE C.V. is an Unknown Business Entity located in Mexico. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1846.) - 351 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 352 of 414 PagelD #: 1118 2770. Defendant GMAC HOLDINGS GMBH is a Limited Liability Company located in Germany. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1847.) 2771. Defendant GMAC GERMANY GMBH & CO. KG is a Limited Liability Company located in Germany. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1848.) 2772. Defendant GMAC BANK GMBH is a Limited Partnership located in Germany. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1849.) 2773. Defendant GMAC HOLDINGS U.K. LIMITED is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1850.) 2774. Defendant GMAC UK PLC is is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1851.) 2775. Defendant GMAC INTERNATIONAL HOLDINGS B.V. is is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1852.) 2776. Defendant ALLY CREDIT CANADA LIMITED is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this - 352 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 353 of 414 PagelD #: 1119 action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1853.) 2777. Defendant GMAC INTERNATIONAL FINANCE B.V. is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1854.) 2778. Defendant ABA SEGUROS, SA. DE C.V. is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1855.) 2779. Defendant ALLY INTERNATIONAL INSURANCE COMPANY, LTD. is an entity form unknown with offices in the State of New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1856.) 2780. Defendant GMAC CYPRESS HOLDINGS LIMITED is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1857.) 2781. Defendant BANCO GMAC S.A. is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1858.) 2782. Defendant RESMOR CAPITAL CORPORATION is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1859.) - 353 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 354 of 414 PagelD #: 1120 2783. Defendant RESMOR TRUST COMPANY is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1860.) 2784. Defendant U.S. TRUST CORPORATION is an entity form unknown residing in New York, New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1861.) 2785. Defendant BANK BOSTON is a Delaware entity situated in Massachusetts. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1862.) 2786. Defendant BANK OF AMERICA (Asia) is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1863.) 2787. Defendant CHINA CONSTRUCTION BANK (Asia) CORPORATION LIMITED is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1864.) 2788. Defendant BANK OF AMERICA (Macau) is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1865.) 2789. Defendant CHINA CONSTRUCTION BANK (Macau) is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1866.) - 354 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 355 of 414 PagelD #: 1121 2790. Defendant CHINA CONSTRUCTION BANK (Macau) is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1867.) 2791. Defendant BANK OF AMERICA CANADA is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1868.) 2792. Defendant BANC OF AMERICA SECURITIES LLC is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1869.) 2793. Defendant MBNA AMERICA BANK is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1870.) 2794. Defendant NATIONAL ASSOCIATION is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1871.) 2795. Defendant FIA CARD SERVICES is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1872.) 2796. Defendant NATIONAL ASSOCIATION is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1873.) - 355 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 356 of 414 PagelD #: 1122 2797. Defendant FIA CARD SERVICES, NATIONAL ASSOCIATION is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1874.) 2798. Defendant RED OAK MERGER CORPORATION is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1875.) 2799. Defendant MERRILL LYNCH is an entity form unknown. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1876.) 2800. Defendant MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED is an entity form unknown with its principal place of business in New York Cityl. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1877.) 2801. Defendant BANCAMERICA ROBERTSON STEPHENS is an entity form unknown with its principal place of business in New York, New York. This Defendant is fully subject to jurisdiction in this action pursuant to applicable law. (This Defendant shall be designated as Defendant No. 1878.) 2802. Defendants, and each of them beginning in paragraph 1068 and concluding in paragraph 2,725, are all entities of unknown form, a.) located and doing business in the State of New York, and b.) in the business of creating a negotiation trail of all Defendants' negotiable instruments and other legal paperwork (including, but not limited to promissory notes and assignments) in a way to create an appearance of propriety under the Uniform Commercial Code when in fact there is no propriety - 356 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 357 of 414 PagelD #: 1123 whatsoever and these Defendants are the core of the ponzi and RICO money laundering schemes set forth in detail above. These Defendants have knowingly conspired and assisted in each and every violation of law and the ponzi, RICO and money laundering schemes set forth herein could not have occurred without them These Defendants are collectively referred to hereinafter as "New York Loan Pools." 2803. At all times material hereto, the business of Defendants was operated through a common plan and scheme designed to conceal from Plaintiffs the material facts set forth below. Such facts were also concealed from the public and from regulators, either directly or as successors-in-interest to the business acquired from others. The concealment was completed, ratified and/or confirmed by each Defendant herein directly or as a successor-in-interest as the acquirer of an entire business, and each Defendant performed or has sought to benefit from the tortious acts set forth herein for its own monetary gain and as a part of a common plan developed and carried out with the other Defendants or as a successor-in-interest to the business that did the foregoing. 2804. Plaintiffs allege that each of the wrongful acts or omissions described below was performed either by each Defendant herein, named or unnamed, or ratified and adopted by each Defendant after its occurrence. 2805. Further, those Defendants that did not actively perform the acts or omissions described in this Complaint did affirmatively aid and abet the other Defendants in the performance of such acts of omissions, before, during or after the fact. 2806. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein. - 357 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 358 of 414 PagelD #: 1124 2807. All Defendants agreed to work together in the conspiracy and/or joint enterprise described in this Complaint based upon an express agreement among all Defendants to convert plaintiffs' monies and personalty in the manner described herein. Accordingly, each Defendant, named or unnamed, should be held liable for the acts and omissions of all other Defendants with respect to the causes of action set forth below. 2808. The true names and capacities of the Defendants listed herein as DOES 2 through 1,000 are unknown to Plaintiffs who therefore sue these Defendants by such fictitious names. Upon learning the true names and capacities of the DOE Defendants, Plaintiffs shall amend this Complaint accordingly. 2809. Each of the Defendants herein, named or unnamed, was the agent of each of the other Defendants herein, named or unnamed, and thereby participated in all of the wrongdoing set forth below. Thus, each such Defendant is responsible for the acts, events and concealment of every other such Defendant as set forth below. 2810. Defendants' wrongful acts include (but are not limited to) the following: (i) claiming to be servicer of the subject notes at issue herein and demanding monthly loan payments therefor, when in fact no Defendant had or has any legal claim to the monies paid to it by Plaintiffs; (ii) taking loan payments every month from each Plaintiff without crediting any portion of that money to the benefit of any Plaintiff; (iii) promising loan modifications to Plaintiffs while never being an authorized legal representative of any person in a position to actually modify Plaintiffs' loans; (iv) inducing Plaintiffs to default on their loans so that Defendants could profit from the credit default swaps they had purchased, betting that such loans would not be paid as - 358 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 359 of 414 PagelD #: 1125 agreed; (v) creating false reasons for charging fees to Plaintiffs based upon nonexistent monies owed, then instituting foreclosure proceedings against Plaintiffs when such fees went unpaid; (vi) issuing wrongful Notices of Default to Plaintiffs; (vii) by refusing to respond, in any way, to Plaintiffs' communications or to communications made for Plaintiffs by their private and public representatives; (viii) converting Plaintiffs' monies as alleged in great detail below, (ix) secreting such acts of conversion through the massive international network used by defendants to support their Ponzi scheme in violation of law. VI. ADDITIONAL FACTS OF THE RICO, MONEY LAUNDERING AND PONZI SCHEMES 2811. This is the largest scheme in United States history where domestic banking institutions - on an international basis, involving all Defendants herein and their co- conspirators operating together in a common enterprise as set forth below - engaged in an institutional, worldwide scheme to steal, rob and convert the personal property, money and proceeds of such assets 3 of each Plaintiff herein on the dates, in the sums and with the modus operandi set forth below. 2812. This modus operandi of Defendants herein includes their decade-long and systematic conversion and "Ponzi scheme" approach that damaged millions of borrowers across the United States. 2813. Defendants' elaborate scheme consisted of - and continues to consist of - numerous business designs, structures and arrangements operated by all Defendants herein. These have included enterprises of each Defendant as set forth herein, that dealt in the converted assets of tens of thousands of American homeowners - To be clear, Plaintiffs make no allegation whatsoever that any Defendant herein - individually or in conspiracy with any other Defendant - has converted any real property. - 359 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 360 of 414 PagelD #: 1126 including the Plaintiffs herein— and secretly transferred them nationally and internationally into a gigantic ongoing "Ponzi scheme." 2814. Because of the economic meltdown of 2007 and beyond, this Ponzi scheme has required the creation of more and more shell entities, and other money-raising vehicles used by Defendants herein in order to support the raising of additional money in order to continue to hide the converted assets. 2815. The entire purpose of Defendants' Ponzi/RICO scheme has been to hide the converted assets of Plaintiffs (and other victims similarly situated) deeply and entirely so that Plaintiffs and other victims become incapable of ever recovering the funds and personalty converted from them. 2816. The assets unlawfully converted and stolen by all Defendants as a part of their conspiracy, as well as instrumentalities used by all Defendants to continue the conversion and secreting of Plaintiffs' assets that are known as of the date of filing hereof, included and continue to include the following: a. Plaintiffs' money, as set forth below (conversion); b. Negotiable instruments improperly negotiated under state and federal law, as set forth below (instrumentality); c. Private identity information of certain Plaintiffs, as set forth below (conversion); d. Other private information of certain Plaintiffs taken by Defendants in violation the provisions of the United States Constitution, as alleged below (conversion); e. Mortgages or deeds of trust transferred secretly in violation of law, as set forth below (instrumentality); - 360 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 361 of 414 PagelD #: 1127 f. Mortgaged-backed securities used merely to shield and hide the movement of assets converted from Plaintiffs outside of the United States (instrumentality); g. Bond or debt securities - which Defendants began calling "hybrid" securities during the pendency of this action - used merely to perpetuate the Ponzi scheme and thus shield and hide the movement of assets converted from Plaintiffs outside of the United States (instrumentality); h. Money laundering of proceeds of the above-described activity, as set forth in detail below (conversion and instrumentality); i. Conversion and larceny where Defendants, and each of them, intended to and did in fact use Plaintiffs' money and other converted property to perpetuate their Ponzi schemes through the use of thousands of companies internationally - funded with converted monies for the purpose of hiding the trail of conversion and secretion - involving trillions of dollars. 2817. Without Defendants' theft of Plaintiffs' money and other property - as alleged herein - none of the mortgage, securities, money laundering and/or Ponzi schemes described herein could have been initiated, perpetuated or maintained. The money converted from the Plaintiffs and other consumers nationwide has always been the "fuel" for the schemes alleged herein. 2818. Included in the scheme as a key instrumentality - but not the fundamental purpose of the scheme - was and is all Defendants' intention to foreclose on the homes of homeowners, including Plaintiffs herein, with respect to promissory notes that are each void ab initio as a result of all Defendants' intentional violation of state and federal laws promulgated to assure complete transparency and compliance with all - 361 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 362 of 414 PagelD #: 1128 applicable laws with respect to the appropriate and lawful negotiation and transfer of such negotiable instruments. 2819. Each Defendant herein is the agent, servant, and co-conspirator of each other Defendant and all Defendants herein operated with their core modus operandi to steal and convert the money and valuable personal property of each Plaintiff (and thousands of other victims) and then to transfer that stolen money (and property) to (a) the other Defendants herein, and to (b) other entities in at least 30 foreign countries according to proof. 2820. In addition, Defendant BofA has admitted the involvement of co-conspirators (a) located in countries without treaties with the United States of America and (b) pursuant to instruments and prospectuses that purport to dissuade (but not expressly prohibit) the involvement of such foreign countries. 2821. Defendants, and each of them, have operated and continue to operate the largest Ponzi scheme in world history with a plan that - at its inception - was intended to, did in fact and continues to the present day to have as its object the theft and conversion of billions of dollars from millions of homeowners, including Plaintiffs. 2822. Plaintiffs became caught up in the tangled Ponzi-scheme-web of Defendants innocently under the guise of applying for a routine home loan or refinancing of an existing home mortgage loan, and have been trying to recover back their money in the sums alleged herein without success ever since. Because of Defendants' intentional and longstanding secretion of their prior and current unlawful conduct, the trail is growing cold and will ultimately be frozen absent the issuance of immediate injunctive relief as prayed for herein. - 362 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 363 of 414 PagelD #: 1129 2823. Defendants have failed and refused to return Plaintiffs' money as alleged herein despite (a) Plaintiffs repeated requests, (b) Defendants' promises to return the money and property, on a consistent month-to-month basis, (c) Interventions by federal and state governments commanding Defendants to either return the money, or provide a transparent plan identifying systems through which money and property could be identified, located and legitimately returned or otherwise accounted for. 2824. The foregoing modus operandi of all Defendants herein - acting in concert with each other and for the common goal of both stealing Plaintiffs money and then hiding any documentary proof thereof - began in 2003. 2825. At that time, each Defendant (or their predecessors) adopted a calculated business strategy that transferred ownership of the promissory notes executed by home loan borrowers to persons that were not entitled to receive negotiation thereof under applicable law, and knew it but joined the conspiracy for purposes that amounted to greed. Such conspiracy has continued to the date of filing hereof, but all Defendants with knowledge and malice aforethought. 2826. Defendant Countrywide and its various affiliates were among the leading providers of mortgages in California during all times relevant to this Complaint. By 2005, Countrywide was the largest U.S. mortgage lender in the United States, originating over $490 billion in mortgage loans in 2005, over $450 billion in 2006, and over $408 billion in 2007. 2827. The other Defendants (or their predecessors in interest, such as WAMU and Wachovia) are the other largest home loan mortgage lenders in the United States, and were all involved in the conspiracy described herein. - 363 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 364 of 414 PagelD #: 1130 2828. The modus operandi of the various Defendants was to use the numerous methodologies set forth in this Complaint to convert money and property from consumers after the origination of their loan. By 2007, this modus operandi had evolved into a massive international Ponzi scheme relying upon foreign investor sources to secure and pay off money injected into the systems of the Defendants by prior lending sources and by Defendants' prior theft of borrower money (including Plaintiffs'). 2829. As of the end of 2007, Defendants had no definitive and reliable knowledge regarding which foreign entity or entities in fact "owned" - as that term is defined under Article 3 of the Uniform Commercial Code — any promissory note secured by any deeds of trust or mortgages securing Plaintiffs' real properties. 2830. Consequently, some of the largest offenders — Countrywide, WAMU, and Wachovia— became hopelessly insolvent and was literally forced by federal regulators to commence negotiations with various large bank to effectuate mergers designed to "clean up" these international Ponzi and conversion schemes. 2831. In 2007, Defendant BofA commenced negotiations to acquire Countrywide. By late 2007, BofA began merging its operations with Countrywide and adopting some of Countrywide 's practices. 2832. WAMU was one of the largest residential mortgage lenders in the United States. However, its predatory lending practices caused it to fail. In September 2008, Chase purchased the assets and liabilities of WAMU for approximately $1.9 billion and began merging it into its operations into Chase by adopting some of its practices. - 364 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 365 of 414 PagelD #: 1131 2833. In 2008, Wachovia was the fourth-largest bank holding company in the United States. However, Wachovia began to fail due to its lending practices, including those described herein. In December 2008, Wells Fargo acquired the assets of Wachovia in order to prevent it from failing, and spent nearly three years merging its operations into Wells Fargo, including adopting some of its practices. 2834. All of the Defendants have taken steps to continue the Ponzi/RICO scheme described herein. Specifically, they have continued to pool mortgage notes into pools for purposes of selling them as so-called mortgage-backed securities, thereby forever severing the promissory notes from the mortgages that secure them. 2835. The Defendants have also acted to foreclose upon homes owned by the Plaintiffs and other individuals by collecting payment in full through a device called a mortgage default swap ("MDS"), whereby the defaulted mortgage would be replaced with a new one. The original lender had already been paid when it transferred the promissory note, so there was no loss to the lender. These lenders foreclose anyway, meaning that they are being paid more than once for the same loan, leading to windfall profits when they sell the properties that they seize through foreclosure. 2836. The fraud perpetrated by the Defendants was willful and pervasive. It began with simple greed and then accelerated when the lenders discovered that they could not sustain their business, unless they (a) used their size and large market share to systematically create false and inflated property appraisals throughout the United States and with respect to each Plaintiff herein and (b) used their network of companies to convert money from unsuspecting borrowers in the United States, - 365 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 366 of 414 PagelD #: 1132 including Plaintiffs, who had good reason at the time to rely upon these fraudulent appraisals and concealment of their intentional, illegal activities. 2837. The Defendants then used these false property valuations, their resulting conversion of monies, and their ongoing Ponzi scheme to finance an operation of agents, including all Defendants and other parties, in order to induce the Plaintiffs and other borrowers into signing documents purportedly confirming ever-larger "refinancing" of their existing mortgages, or to execute promissory notes so that the Defendants could later convert more money and property from them. 2838. The Defendants either knew, or should have known, no later than 2004, that these loans were unsustainable for the lenders and the borrowers and to a certainty either knew or should have known that their fraudulent activity would result in a crash that would consume the equity invested by the Plaintiffs and all other borrowers. 2839. The Defendants either knew, or should have known, no later than 2004, that the foregoing misconduct would result in their ability to convert monies from Plaintiffs (and thousands of other homeowners) subsequent to their pooling of these promissory notes as mortgage -backed securities ("MBS") that would be sold on the open market to various institutional investors for inflated values. 2840. This system led to the Defendants making multiple sales of the same promissory notes to multiple MBS pools. These multiple sales of the same promissory notes to multiple buyers do not create ownership of such negotiable instrument under Article 3 of the Uniform Commercial Code. 2841. The plan to pool these loans into MBS offerings grew into a brazen plan to disregard underwriting standards and fraudulently inflate property values - county- - 366 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 367 of 414 PagelD #: 1133 by-county, city-by-city, person-by-person - in order to take business from legitimate mortgage-providers, and developed into a massive securities fraud that depended on the concealment from and deception of the Plaintiffs as to the true nature of these transactions on an unprecedented scale. In this way, the Defendants would be able to convert money from the Plaintiffs without such Plaintiffs having any idea or knowledge of the dirty and unlawful plot at the time it was being implemented. 2842. As early as 2004, the Defendants either knew or should have known that this scheme would cause a liquidity crisis that would devastate the Plaintiffs' home values and net worth. 2843. The Defendants did not care, because their plan was based on insider trading - pumping for as long as they could and then dumping before the truth came out and the theft and conversion of money and assets from Plaintiffs as well as the general public were locked in. 2844. Couched in banking and securities jargon, the deceptive gamble with consumers' primary assets - their homes - was nothing more than a financial theft and concurrent Ponzi scheme perpetrated by Defendants and their co-conspirators on a scale never before seen. 2845. This scheme led directly to a nationwide mortgage meltdown that was substantially worse than any economic problems facing the rest of the United States, thereby causing the failure of numerous lenders. 2846. From 2008 to the present, Americans' home values decreased substantially as a direct and proximate result of the Defendants' scheme set forth herein, leaving a large percentage of homeowners "upside down", meaning that they owe more on their - 367 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 368 of 414 PagelD #: 1134 home mortgage loans than their homes are worth. In some instances, those homes are so far upside down that it could take a decade or more for the homeowners to regain a positive position with respect to the value of their homes. 2847. This massive fraudulent scheme was a disaster both foreseen by the Defendants as well as waiting to happen. Defendants knew it, and further knew that the taxpayer money would bail out those lenders deemed too big to fail. 2848. The lenders involved - Defendants herein - embarked on a plan and scheme to use the good faith of taxpayer money and the country's trust and confidence in the big banks that acquired Countrywide, WAMU, and Wachovia to (a) further hide their nefarious conversion scheme, (b) engage in additional acts of conversion and secreting of the knowledge thereof and (c) use new laws and initiatives as a basis to induce unsuspecting homeowners to fall further victim to their ongoing expansion of the foregoing scheme throughout the world. 2849. As a result, the Plaintiffs lost money and any ability to actually pay off their promissory notes, their credit ratings and histories were damaged or destroyed, and they also incurred material other costs and expenses, all as described herein. 2850. At the same time, Defendants converted from Plaintiffs and other borrowers across the country billions of dollars in interest payments and fees and generated billions of dollars in profits by vastly expanding the scheme previously unique to just a few predatory lenders such as Countrywide and now subject to the power of (a) a new, larger and more credible parents, such as BofA, Chase, and Wells Fargo and (b) the influx of new dollars in the form of taxpayer money and increased investment by - 368 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 369 of 414 PagelD #: 1135 investors knowledgeable of the Ponzi scheme to such an extent that they were co- conspirators in it. 2851. The Defendants then began to use their customers' most private information to maximize their illegal gains, ranging from the disclosure of the most private and confidential information of more than 2.4 million customers, to the outsourcing and sale of hundreds of thousands of records to bolster their fraudulent scheme, disenfranchising citizens of their constitutional inalienable right of privacy. 2852. When the Defendants pooled the loans they originated and sold in MBS secondary mortgage market transactions, those lenders recorded gains on the sales. In 2005, Countrywide reported $451.6 million in pre-tax earnings from capital market sales; in 2006, it recognized $553.5 million in pre-tax earnings from that activity. 2853. However, after the liquidity crisis hit, in 2007 it recognized a mere $14.9 million in pre-tax earnings from that activity and reported an overall pre-tax loss. 2854. In addition, there is a lot of confusion, even among the mortgage companies, as to the ownership history of many mortgage loans. In the mad rush to convert home mortgages into securities to be bought and sold on Wall Street, investors did not want to spend the time or money necessary to keep track of ownership by filing papers in local recording offices. 2855. Investors by-passed the traditional systems and replaced them with the MERS system, which is not only inherently unreliable and unverifiable, it also remains outside the public eye. - 369 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 370 of 414 PagelD #: 1136 2856. As a result, it is no longer possible for most Americans to go to their local courthouse and look at property records to find out who the owner of their mortgage currently is. 2857. To make matters worse, the Defendants established their concealment network now alleged entity-by-entity in this complaint, and this network has made it impossible to track the negotiation techniques and rights to possession of promissory notes, which are not publicly recordable. 2858. The illegal and improper acts of the Defendants have continued, including, inter alia: (i) engaging in the practice of "robo-signing," whereby the lenders used people who had no personal knowledge to sign fraudulent and perjured affidavits that indicated that they had personal knowledge of those matters in an effort to deprive homeowners of their property without due process of law; (ii) refusing to modify loans; and (iii) refusing to entertain short sale opportunities, all with the intention to (a) buy time to further conceal previous conversions and/or (b) convert additional monies from the Plaintiffs in a sum according to proof. 2859. Many of the Plaintiffs were told not to make mortgage payments and/or to sign letters authored by agents of Defendants, exacerbating a desperate financial situation that was either untrue or inflated at Defendants' insistence. This was all done in order to buy time for Defendants to further secret the conversion of funds practiced against the Plaintiffs and to support other conversions of monies that Defendants were bent on practicing. 2860. Defendants have gone to great lengths to avoid identifying the location of monies and property converted by them from Plaintiffs. The gigantic network of Defendants - 370 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 371 of 414 PagelD #: 1137 and their co-conspirators-companies formed in countries such as the Cayman Islands, Luxembourg, Gibraltar and Chile for the purpose of hiding assets and laundering money-has been, and continues to be, used to systematically hide and ultimately destroy the evidence revealing the method of conversion used and the location of the money and personalty converted by Defendants. 2861. By these tactics, systems, and delays, Defendants intend to and are in fact buying time as they (a) accept the benefits of the Ponzi scheme and conversion activities described herein, (b) cover up their historical conversion and Ponzi scheme, and (c) make it materially more expensive and difficult for the Plaintiffs to locate their stolen assets and gain recompense. 2862. Defendants herein include some of our leading financial institutions - institutions upon which the Plaintiffs thought they could rely, and did in fact rely upon. However, their reliance was misplaced. As is clear from the mounting number of federal and state enforcement actions against Defendants, it is now widely recognized that they have committed numerous illegal acts in the process of operating their mortgage businesses. BofA alone has been sued for trillions of dollars as a result of its involvement in these activities. 2863. These acts remain ongoing, and continue to threaten the Plaintiffs' constitutional rights and financial security, as well as the economic future of the United States of America. 2864. The Defendants either knew or should have known that the scale of the lending - based on inflated property values, without income verification and in violation of numerous other underwriting guidelines - would lead to widespread declines in - 371 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 372 of 414 PagelD #: 1138 property values, thereby placing Plaintiffs and others into extremis through which they would lose the equity invested in their homes and have no means of refinancing or selling, other than at a complete loss. 2865. That is precisely what happened to the Plaintiffs herein after Defendants converted their money and the equity in their homes, but before Plaintiffs could have possibly realized the ultimate purpose of the Defendants' scam. 2866. While the following quotation, taken from a regulatory report, refers specifically to Countrywide, which was portrayed as a prudent, quality lender, it also applies to the business practices of all Defendants. "But the real Countrywide was very different. We allege it was a company that underwrote loans in a manner that layered risk factor upon risk factor, such as reduced documentation . . . [a]lso concealed from investors were concerns voiced by Countrywide 's own Chief Credit Risk Officer, who warned that this 'supermarket' strategy reduced Countrywide 's underwriting guidelines to a 'composite of the riskiest products being offered by all of their competitors combined.'" 2867. The Defendants held themselves out as makers of prime quality mortgage loans, but instead hid the fact that they, in an effort to increase their respective market shares, engaged in an "unprecedented expansion of its underwriting guidelines from 2005 and into 2007." Specifically, the Defendants developed what was referred to as a "supermarket" strategy, where they attempted to offer any product that was or might be offered by any competitor. 2868. By the end of 2006, Defendants' underwriting guidelines were as wide as they had ever been, and they were writing riskier and riskier loans. Even these expansive - 372 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 373 of 414 PagelD #: 1139 underwriting guidelines were not sufficient to support their desired growth, so the lenders wrote an increasing number of loans as "exceptions" that failed to meet their already wide underwriting guidelines even though exception loans had a higher rate of default. 2869. The covert scheme of the Defendants was, like all such schemes based on deception, ultimately unsustainable. The Defendants relied upon their sales of mortgages into the secondary marked through MBS instruments as an important source of revenue and liquidity. 2870. The Defendants not only covered up the poor quality of their loans and the liquidity crisis they created, they intentionally misrepresented to the public, in statements and in public filings, the nature of those loans in an effort to further defraud the public into continuing to borrow money and put their assets at risk. 2871. The Defendants' scheme eventually collapsed under its own weight, precipitating an economic crisis of unprecedented proportions. 2872. As defaults on these poorly underwritten loans increased, Defendants used the opportunity presented by the rising number of defaults to increase their fees and further convert other funds from Plaintiffs and other borrowers. 2873. To add insult to injury, as the number of defaults rapidly rose, the Defendants added unreasonable additional fees to the mortgages of homeowners who were desperately trying to save their homes, thereby boosting their profits at the expense of those who could least afford to bear that burden. 2874. Defendants did the foregoing with the intent to convert funds from the Plaintiffs and other members of the public. The Plaintiffs did not know the massive scheme that - 373 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 374 of 414 PagelD #: 1140 the Defendants had devised and never knew until it was far too late to prevent the massive network being used across the globe to hide the trail of converted money and property. 2875. As a proximate and foreseeable result of the Defendants' sale of the promissory notes pertaining to the properties of the Plaintiffs and others similarly situated for more than the actual value of such instruments, the MBS securitization pools lacked the cash flow necessary to maintain them in accordance with the terms of their indentures. The unraveling of Defendants' scheme has materially depressed the price of real estate throughout the country, including the real estate owned by the Plaintiffs, resulting in the losses to the Plaintiffs described herein. The conversion of Plaintiffs' money by Defendants - and each of them operating through their RICO scheme - has materially injured the tangible net worths of Plaintiffs and the Treasury of the United States of America. 2876. The Defendants have made use of wholly or partially owned foreign companies in an effort to continue to hide and to misrepresent the ownership of the promissory notes executed by the borrowers, including the Plaintiffs, who borrowed funds from them. 2877. BofA, Chase, and Wells Fargo have ratified the bad acts of WAMU, Countrywide, and Wachovia, by intentionally making use of foreign companies to frustrate the Plaintiffs and other borrowers seeking information about their lost money, mortgages and loan modifications. All Defendants have joined in this conspiracy - indeed most Defendants were formed for purposes associated with the money laundering, ponzi and RICO enterprises set forth herein. All Defendants have - 374 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 375 of 414 PagelD #: 1141 acted in conspiracy with one another appertaining to each and every act set forth in this complaint. FIRST CLAIM FOR RELIEF Conversion (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2878. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2879. All Defendants have demanded and received payments from the Plaintiffs based upon the claim of these Defendants that such monies are owed on the loans and promissory notes at issue herein. 2880. These Defendants have further demanded and received from Plaintiffs payments, imbursements for late charges, penalty fees, and trial loan modification payments. 2881. In truth, on information and belief, these Defendants had and have no legal right to be demanding such payments from Plaintiffs for any loans or promissory notes or loan modifications at issue herein because these Defendants are not holders or owners of the promissory notes in question and they no longer know who is. 2882. Further, Defendants are not the authorized representative or agent for the holders or owners of the promissory notes in question. 2883. In truth, the monies collected from the Plaintiffs by these Defendants was not credited for the benefit of the individual Plaintiffs involved, in that it was not used to - 375 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 376 of 414 PagelD #: 1142 pay down that Plaintiffs (or any Plaintiffs) principal and/or interest purportedly due on his or her promissory note. 2884. Thus, in taking monies from Plaintiffs as described above, these Defendants are liable to Plaintiffs herein for conversion, i.e., the act of dominion wrongfully exerted over another person's personal property. In taking the money from Plaintiffs as described above, Defendants converted between $35,000 and $70,000 per Plaintiff over the course of their business dealings with Defendants. Defendants had no right to these funds and engaged in money laundering both domestically and internationally in order to hide the theft, larceny and conversion set forth herein. It is impossible for Plaintiffs to know with certainty the exact amount of funds converted because Defendants have provided inconsistent, varying and false accounts of the monies they have received from Plaintiffs herein. 2885. These claims of conversion are based upon the facts that a) each Plaintiff had ownership and the right to possession of the monies taken from him by these Defendants as described above; b) these Defendants acted wrongfully by receiving such money under the guise that the Defendants were entitled to the money, when in fact they were and are not entitled to any such payment; c) no money collected by these Defendants from these Plaintiffs was credited to the benefit of the individual Plaintiff involved for the pay down of any principal or interest purportedly due on that Plaintiffs note; and d) each Plaintiff suffered general and special damages, including loss of the money that was taken from them by these Defendants through this subterfuge, according to proof. - 376 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 377 of 414 PagelD #: 1143 2886. These Defendants also committed conversion as against each Plaintiff by converting equity that previously existed in each Plaintiffs home - in sums according to proof - by surcharging against that equity various false "reserves" in the form of "insurance" or "tax" or "general" reserve imbursements, which were then recorded as debts against the property of the individual Plaintiff involved. 2887. Just as banks are liable to a customer and must credit his account for conversion when banks pay on a forged indorsement of a commercial instrument, so too are these Defendants liable for these false surcharges improperly charged against a Plaintiff's account. 2888. As a direct and proximate result of the conversion committed by the Defendants, each Plaintiff suffered general and special damages according to proof. 2889. Each Plaintiff is further entitled to restitution of those amounts wrongfully converted from him or her. 2890. These Defendants willfully committed the wrongdoing against each Plaintiff as described herein and knowingly chose to deceive him or her in the above-described manner. Thus, the acts of these Defendants were malicious and performed with a callous disregard for Plaintiffs' legal rights. Plaintiffs are therefore entitled to punitive damages. Plaintiffs are further entitled to attorney fees under whatever contract or statute applies. 2891. All Defendants have converted and stolen - in the manner, using the means of interstate commerce as set forth herein - the sum of at least between $40,000.00 and $60,000.00, from each Plaintiff herein. 2892. In no event has any Plaintiff herein suffered damages greater than $75,000.00. - 377 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 378 of 414 PagelD #: 1144 SECOND CLAIM FOR RELIEF Conspiracy to Commit Conversion (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2893. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2894. Plaintiffs allege that each of the wrongful acts or omissions described in the First Cause of Action for Conversion above was either performed by each Defendant herein, named or unnamed, or ratified and adopted by each Defendant after its occurrence. 2895. Further, those Defendants that did not actively perform the acts or omissions described here did affirmatively aid and abet the other Defendants in the performance of such acts or omissions, either before, during, or after the fact in the form of concealment and secretion activities worldwide. Such activities represent additional acts of conversion under law. 2896. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein. All Defendants agreed to work together in the conspiracy and/or joint enterprise described in this Cause of Action as set forth herein. Accordingly, each Defendant, named or unnamed, should be held liable for conspiracy to commit the conversion as alleged in the First Cause of Action. - 378 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 379 of 414 PagelD #: 1145 2897. The Plaintiffs are entitled to the damages as alleged and described in the First Cause of Action - and as alleged above - as a direct and proximate result of this conspiracy of all Defendants to commit repeated and serial acts of conversion against these Plaintiffs as described herein. 2898. These Defendants willfully committed the wrongdoing against each Plaintiff as described herein and knowingly chose to deceive him in the above-described manner. Thus, the acts of these Defendants were malicious and performed with a callous disregard for Plaintiffs' legal rights. Plaintiffs are therefore entitled to punitive damages. 2899. In no event has any Plaintiff herein suffered damages greater than $75,000.00. THIRD CLAIM FOR RELIEF Intentional Misrepresentation (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2900. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2901. The Defendants intentionally misrepresented to the Plaintiffs and to the consuming public in general their intentions regarding the reasonableness and appropriateness of their underwriting procedures in making mortgage loans to the Plaintiffs, and also materially misrepresented to the consuming public that they were not making quality loans when they told the consuming public that they were only making quality, prime home loans. - 379 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 380 of 414 PagelD #: 1146 2902. The Defendants intentionally misrepresented to the public at large the status of their liquidity and the quality of the loans that they were making. 2903. Those Defendants further intentionally misrepresented to the Plaintiffs that they would not use or otherwise impose unreasonable or unfair charges against the Plaintiffs and the rest of the consuming public, but they failed to do so. 2904. The campaign of concealment, misinformation and partial information described in this Cause of Action as well as in the rest of this Complaint was intended to be repeated and also to be broadly disseminated through the media, analyst reports and individual communications, and it was. 2905. It was intended to become part of the well-understood "givens" among homeowners and prospective homeowners seeking mortgages, and it did so become part of the lexicon of homeownership and mortgage choices. 2906. These Plaintiffs relied upon the misrepresentations and entered into mortgages with the Defendants. 2907. All of said intentional misrepresentations and omissions were made by the Defendants with the intent to induce the consuming public, including the Plaintiffs, to enter into mortgage loan transactions that would deprive them of the equity in their homes. 2908. By reason of the prominence of the Defendants and their campaign of deception as to their business plans and the relationship of trust developed between each of the Defendants and the Plaintiffs, Plaintiffs were justified in relying upon Defendants' representations. - 380 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 381 of 414 PagelD #: 1147 2909. At all times pertinent, the Plaintiffs in fact reasonably relied upon the representations made by the Defendants that they would use reasonable and rational underwriting guidelines in making mortgage loans to the consuming public and entered into mortgage loan contracts with the Defendants, all to their injury and detriment. 2910. In fact, the appraisals were inflated. The Defendants did not utilize appropriate underwriting processes. The financial condition of the various Defendants was not sound, but rather was a house of cards ready to collapse. Further, Plaintiffs' mortgages were not refinanced with fixed rate mortgages as they were told they would be, and the Defendants never intended that they would be. 2911. As a result of Defendants' scheme described herein, these Plaintiffs could not afford their adjustable rate mortgages when their variable rate features and/or balloon payments kicked in. 2912. Further, and as a result of the nefarious scheme of the Defendants, the Plaintiffs could not refinance or sell their residences without suffering a loss of their equity investments. 2913. As a result of the foregoing acts of conversion and fraud, the Plaintiffs have lost all or a substantial portion of the equity invested in their houses and suffered reduced credit ratings and increased borrowing costs, among other damages described herein. 2914. As a result of the Defendants' misconduct alleged above, all negotiable instruments appertaining or relating to Plaintiffs - whether or not an original or any copy thereof is held by Defendants or any of their co-conspirators in their money laundering schemes - may be declared to be void ab initio as determined by the trier - 381 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 382 of 414 PagelD #: 1148 of fact. In the event of such a finding by the trier of fact - that these negotiable instruments are void ab initio - leads to a recovery for any Plaintiff, along with all damages awarded herein, of a sum total of more than $75,000.00, each Plaintiff generally and specifically waives, gives up, and disavows any such recovery in excess of $75,000.00. Nothing set forth herein, however, should be construed to infer that Plaintiffs agree to deprive the trier of fact of the right to adjudicate whether negotiable instruments pertaining to them were or were not void ab initio, as such a determination will impact the predicate conduct required for an award of punitive damages and may impact other areas of Plaintiffs' case such that they are not required to, and do not, in fact, agree to allow such critical issue to avoid scrutiny by the trier of fact in this case. 2915. These Plaintiffs are further entitled to punitive damages in order to punish these Defendants for their malicious, oppressive and willful conduct as described. 2916. Inclusive of all compensatory damages, special damages, attorney fees and punitive damages alleged herein, each Plaintiff has sustained damage in a sum of not greater than $75,000.00. FOURTH CLAIM FOR RELIEF Intentional Misrepresentation (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2917. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. - 382 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 383 of 414 PagelD #: 1149 2918. In addition to the numerous acts of fraud described above, the Defendants represented to multiple Plaintiffs and to the consuming public in general that the Defendants would assist them in accomplishing a loan modification. As described herein, those representations were false. 2919. Defendants knew that their representations regarding their willingness to enter into loan modification agreements were false when they made them. 2920. Because of new laws pertaining to loan modifications combined with the insistence of the Defendants that they had a genuine interest in complying therewith and in keeping borrowers in their homes, the Plaintiffs reasonably relied on these materially false misrepresentations made by the Defendants. 2921. By delaying the Plaintiffs from pursuing their rights and by increasing the costs of the Plaintiffs combined with the continuing erosion of each Plaintiff's credit rating, each Plaintiffs reliance harmed that particular Plaintiff. 2922. The Plaintiffs' reliance on the representations made by the Defendants was a substantial factor in causing harm to them. 2923. Without limiting the damages as described elsewhere in this Complaint, the damages of the Plaintiffs arising from the matters complained of in this Cause of Action also include the loss of equity in their houses, costs and expenses related to protecting themselves, reduced credit scores, unavailability of credit, increased costs of credit, reduced availability of goods and services tied to credit ratings, increased costs of those services, as well as fees and costs, including, without limitation, attorney fees and costs. - 383 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 384 of 414 PagelD #: 1150 2924. The Plaintiffs are entitled to recover general and special damages directly and proximately resulting from the Defendants' intentional deceit and misrepresentations. 2925. These Plaintiffs are further entitled to punitive damages in order to punish these Defendants for their malicious, oppressive and willful conduct as herein described. 2926. Inclusive of all compensatory damages, special damages, attorney fees and punitive damages alleged herein, each Plaintiff has sustained damage in a sum of not greater than $75,000.00. FIFTH CLAIM FOR RELIEF Fraudulent Concealment (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2927. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2928. Defendants have offered to help the Plaintiffs with obtaining "loan modifications" while concealing from these Plaintiffs the fact that, upon information and belief, these Defendants are not the rightful owners and/or holders of the subject promissory note associated with their mortgages. 2929. The Defendants have also failed to disclose that they are not the legal representatives or agents of such persons, and they have further failed to disclose that the Defendants' entire motivation and purpose in doing so has been, and continues to be, the conversion of Plaintiffs' monies and the taking of their homes in violation of law. - 384 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 385 of 414 PagelD #: 1151 2930. Thus, these Defendants are legally incapable to be able to enter into loan modifications with any Plaintiff. 293 1 . Despite that fact, the Defendants have had and continue to have a vested interest in "offering loan modifications" to borrowers, including the Plaintiffs, because they can make a profit from continuing to cover up the industry-wide scheme alleged above and to create an environment where they can commit additional acts of fraud and conversion. 2932. In fraudulently offering loan modifications to Plaintiffs, the Defendants have convinced Plaintiffs that loan modifications will only be given to those borrowers that are delinquent on their loans and/or in default. 2933. The Defendants have made these statements on an industry-wide basis in order to permit them to continue their scheme of obtaining monies and properties from Plaintiffs wrongfully and in violation of law. 2934. In reliance upon these materially false representations, and in the belief that they would be able to obtain loan modifications if they followed these false and misleading instructions, Plaintiffs have permitted their loans to go delinquent and/or into default, believing this step to be a requisite of the loan modification process. 2935. At all times relevant, the Defendants possessed superior knowledge to that of the Plaintiffs, and further had access to material facts that were not accessible to the Plaintiffs regarding their nefarious scheme to induce the Plaintiffs to permit their mortgages to go into default in the hope of obtaining loan modification. 2936. At all times relevant, Defendants had an affirmative duty to disclose to the Plaintiffs that Defendants had no legal authority to offer loan modifications. - 385 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 386 of 414 PagelD #: 1152 2937. However, the Defendants have hidden and suppressed the fact that they do not own the subject promissory notes and hence have no legal or contractual authority to offer such loan modifications. 2938. The Defendants also had an affirmative duty to disclose to the Plaintiffs that Plaintiffs did not have to be in default on their loans in order to qualify for loan modifications. 2939. Defendants have induced the Plaintiffs into allowing their loans to go into default by telling Plaintiffs it was a requirement for becoming eligible for a loan modification 2940. In truth, under applicable law in effect since 2009, a borrower is not required to be delinquent and/or in default with his loan in order to be eligible for a loan modification. 2941. Defendants have only claimed that borrowers must be in default, in violation of law, because Defendants can realize more profit and commit more acts of conversion when a borrower is actually in default, i.e., at least 90 days behind in his loan payment 2942. After Defendants profited by their deceit and concealment, they then continued demanding and collecting monies from Plaintiffs, constituting outright conversion. 2943. The fact that these Plaintiffs did not need to be delinquent on their loans and/or in default in order to qualify for loan modifications has been hidden and suppressed from these Plaintiffs by Defendants and continues to be hidden. 2944. The Defendants should have disclosed these suppressed facts to the Plaintiffs because they were material to the cost-benefit analysis that should have and could have been undertaken by each Plaintiff. - 386 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 387 of 414 PagelD #: 1153 2945. Had the true facts been disclosed to the Plaintiffs, knowledge of those material facts likely have caused each Plaintiff (a) to act differently than he or she did while not knowing the facts hidden from him by Defendants, and (b) to protect himself or herself by not preventing his or her funds from being converted by Defendants. 2946. The Defendants knew these suppressed facts and further knew at the time of their suppression, that such suppression and concealment would cause each Plaintiff to act in a way that was injurious to him or her while at the same time being profitable to Defendants. 2947. When suppressing and concealing from the Plaintiffs these material facts as herein alleged, Defendants intended to induce each such Plaintiff to alter his or her position to his or her harm. 2948. Each Plaintiff justifiably and reasonably relied on the fraudulent concealment created by these Defendants in their suppression and concealment of the material facts described above. 2949. Once a Plaintiff became delinquent in his or her loan payments, Defendants then acted to ensure that the delinquency became a default under the terms of the loan documents. 2950. Defendants achieved this by asking each Plaintiff applying for a loan modification to submit the proper application and paperwork. Once a Plaintiff submitted all documents as requested, the Defendants then claimed to have "lost" the Plaintiffs application package, necessitating the re-submission of such documents by each Plaintiff hoping to qualify for a loan modification. - 387 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 388 of 414 PagelD #: 1154 2951. During this process, Defendants would collect and convert the maximum amount of money from Plaintiffs in sums according to proof. 2952. This process of "losing the paperwork" and requiring re-submission thereof necessarily ensured that a Plaintiffs one or two-month "delinquency" automatically became a "default," and an event requiring significant payments to Defendants to cure said "default," all of which constituted misappropriation and conversion of funds under law. 2953. These Defendants regularly dragged out this process for months and months when dealing with Plaintiffs in need of loan modifications. They did so by claiming over and over again to have "lost" the paperwork of the borrower involved. 2954. Each Plaintiff was directly and proximately harmed by Defendants' fraudulent concealment of facts described herein. 2955. Plaintiffs have incurred additional costs and charges and late fees as a result of being told that they needed to be delinquent in their loans in order to obtain a loan modification. 2956. Plaintiffs have gone into default and even lost their homes through foreclosure as the result of the same fraudulent concealment by Defendants. 2957. Further, Plaintiffs have had their credit profiles destroyed by allowing their loans to go into default as instructed by Defendants. 2958. Accordingly, each Plaintiff is entitled to general and special damages according to proof at trial. 2959. Further, the Defendants acted outrageously and persistently with actual malice in suppressing the facts and circumstances set forth, and they continue to do so. - 388 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 389 of 414 PagelD #: 1155 Accordingly, the Plaintiffs are entitled to exemplary and punitive damages in a sum according to proof. 2960. The Defendants willfully committed the wrongdoing against each Plaintiff as described herein and knowingly chose to deceive him in the above-described manner. Thus, the acts of the Defendants were malicious and performed with a callous disregard for Plaintiffs' legal rights. Plaintiffs are therefore entitled to punitive damages. Plaintiffs are further entitled to attorney fees under whatever contract or statute applies. 2961. Inclusive of all compensatory damages, special damages, attorney fees and punitive damages alleged herein, no Plaintiff has sustained damage in a sum greater than $75,000.00. SIXTH CLAIM FOR RELIEF Fraudulent Concealment (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2962. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2963. As set forth in the Fifth Cause of Action, the Defendants used fraud and artifice to lure borrowers into defaulting upon their mortgages by promising them loan modifications when they had no intention of providing such loan modifications. 2964. Once the Defendants lured a borrower into default, then the Defendants collected upon "credit default swaps" ("CDS's"). - 389 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 390 of 414 PagelD #: 1156 2965. CDS's were and are used to insure mortgage-backed securities, and investor trading in these two instruments was the central cause of the mortgage meltdown that occurred in this country. 2966. A CDS is a form of insurance that is actually a bet against the subject loan being paid on time as agreed. CDS's ensure that Defendants can collect on every loan that goes bad by going into default. 2967. If a borrower defaulted upon a mortgage that was pooled into an MBS, the buyer of the CDS makes a series of payments (the CDS "fee" or "spread") to the seller and, in exchange, receives a payoff if the loan defaults. Thus, the original lender was paid when it sold the promissory note executed by the borrower, and the MBS pool was also paid in full by virtue of the CDS payments received. 2968. This, then, constitutes the number one reason that the Defendants wanted each Plaintiff to actually default on his or her loan: The Defendants bet against each Plaintiff by buying CDS's on every loan they allegedly service, and then trying to get that loan into default so that the Defendants can collect on this "side bet." 2969. The fact that the Defendants were motivated to see that each Plaintiff failed to pay their mortgages on time and thus ended up in default so that the Defendants could collect on their CDS side bet has been hidden and suppressed from Plaintiffs by the Defendants. 2970. The suppressed facts and circumstances described herein should have been disclosed to the Plaintiffs by the Defendants because such facts and circumstances were material in that they were essential to the analysis that should and could have been undertaken by each Plaintiff in determining whether to enter into a loan - 390 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 391 of 414 PagelD #: 1157 transaction with the Defendants, and would likely have caused each Plaintiff to act differently than he did while not knowing the facts hidden from him by Defendants. 2971. These suppressed facts and circumstances were known to the Defendants at the time they were hidden from Plaintiffs. 2972. Further, the Defendants knew at the time of suppression and concealment that such suppression and concealment would cause each Plaintiff to act in a way that was injurious to him while at the same time being profitable to the Defendants. 2973. When suppressing and concealing from these Plaintiffs the facts and circumstances herein described, the Defendants intended to induce each Plaintiff to alter his position to his harm. 2974. Each Plaintiff justifiably and reasonably relied on the fraudulent concealment created by Defendants in their suppression of the facts and circumstances described in this Cause of Action. 2975. Defendants' receipt of money from CDS's coupled with their later receipt of money from Plaintiffs means that the Defendants have received a windfall in the form of gaining either ownership of the real property of borrowers, or the value of that real property, and is malicious, outrageous, and entitles Plaintiffs to recover exemplary and punitive damages in a sum according to proof. 2976. The Defendants knowingly and willfully committed the wrongdoing against each Plaintiff as described herein and knowingly chose to deceive him in the above- described manner. Thus, the acts of the Defendants were malicious and performed with a callous disregard for Plaintiffs' legal rights. Plaintiffs are therefore entitled to punitive damages. Plaintiffs are further entitled to attorney fees. - 391 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 392 of 414 PagelD #: 1158 2977. Inclusive of all compensatory damages, special damages, attorney fees and punitive damages alleged herein, no Plaintiff has sustained damage in a sum greater than $75,000.00. SEVENTH CLAIM FOR RELIEF Promissory Estoppel (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2978. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2979. Each Plaintiff herein attempted to take steps to save his or her house once it became apparent that Defendants intended to foreclose against them. Some Plaintiffs considered filing bankruptcy as a valid and viable means to save their homes. Other Plaintiffs investigated other possible ways to avoid losing possession of their homes due to Defendants' wrongful tactics as set forth above. 2980. In each instance, Defendants promised to Plaintiffs that there was no need to file bankruptcy or pursue other ways to avoid foreclosure because Defendants would forego the foreclosure process and would instead "work with" each Plaintiff to modify the terms of the home loan in question, thereby making it possible for each Plaintiff to make the necessary monthly payments. 2981. In reliance on the promises made by Defendants not to foreclose and to instead "work with" each Plaintiff, each Plaintiff reasonably decided not to file for - 392 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 393 of 414 PagelD #: 1159 bankruptcy or to investigate other possible scenarios to stave off impending foreclosure. 2982. Instead of cooperating with each Plaintiff and working with them to modify each loan at issue, Defendants instead have proceeded with various levels of conversion and/or foreclosure proceedings against each Plaintiff herein. 2983. In reasonable reliance on Defendants' promises not to foreclose, each Plaintiff has suffered direct and proximate damages as a result of Defendants' bad-faith breach of promises not to exceed $75,000.00. Each Plaintiff is therefore entitled to compensatory damages according to proof within these limitations, in order to make him or her whole. EIGHTH CLAIM FOR RELIEF Negligent Misrepresentation (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2984. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2985. Because the Plaintiffs relied upon the Defendants to guide them through the process of making and later servicing their home mortgage loans, a special relationship exists between the Plaintiffs and the Defendants. 2986. The existence of that special relationship imposed upon the Defendants a duty to fully and accurately disclose all pertinent information pertaining to those home loans to the Plaintiffs, including, but not limited to, true and correct information pertaining - 393 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 394 of 414 PagelD #: 1160 to the securitization of their notes, the existence of CDS, and the fact that the Defendant lenders had no legal right to foreclose upon their mortgages once the promissory notes became the basis for MBS pools. 2987. Defendants failed to disclose this material information to the Defendants, or omitted critical elements from the disclosures that were made. 2988. The Plaintiffs reasonably relied upon the material misrepresentations of the Defendants to their detriment in choosing to proceed with their mortgage loan transactions. 2989. As a consequence of the negligent misrepresentations made by the Defendant to the Plaintiffs, no Plaintiff herein has suffered damages greater than $75,000.00. 2990. Plaintiffs allege that each of the wrongful acts or omissions described in this Cause of Action was either performed by each Defendant herein, named or unnamed, or ratified and adopted by each Defendant after its occurrence. Further, those Defendants that did not actively perform the acts or omissions described here did affirmatively aid and abet the other Defendants in the performance of such acts or omissions, before, during or after the fact. 2991. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein. All Defendants agreed to work together in the conspiracy and/or joint enterprise described in this paragraph as that conspiracy is alleged above. Accordingly, each Defendant, named or unnamed, should be held liable for the acts and omissions complained of. NINTH CLAIM FOR RELIEF Breach of the Covenant of Good Faith and Fair Dealing - 394 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 395 of 414 PagelD #: 1161 (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 2992. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 2993. In each and every mortgage note signed by the Plaintiffs, and in each and every mortgage instrument signed by the Plaintiffs in favor of the Defendants, is implied a covenant of good faith and fair dealing between the parties. 2994. The implied obligation encompasses any promises which a reasonable person in Plaintiffs' position would be justified in understanding was included in the parties' agreement. 2995. The Defendants have breached that covenant of good faith and fair dealing by intentionally and/or negligently misrepresenting or omitting to disclose material facts that would have been pertinent to those Plaintiffs' decisions to enter into transactions with the Defendants. 2996. As a consequence of the breaches of the covenant of good faith and fair dealing by the Defendants, the Plaintiffs have been deprived of the right to receive the benefits under those loan agreements, to-wit: they have been stripped of the value and equity in their homes as a consequence. 2997. Inclusive of all recoverable damages and restitution and costs and attorney fees, each Plaintiff has sustained damage and restitution in the sum of no more than $75,000.00. - 395 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 396 of 414 PagelD #: 1162 2998. Plaintiffs allege that each of the wrongful acts or omissions described in this Cause of Action was either performed by each Defendant herein, named or unnamed, or ratified and adopted by each Defendant after its occurrence. Further, those Defendants that did not actively perform the acts or omissions described here did affirmatively aid and abet the other Defendants in the performance of such acts or omissions, before, during or after the fact. 2999. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein. All Defendants agreed to work together in the conspiracy and/or joint enterprise described in this paragraph in the manner set forth herein. Accordingly, each Defendant, named or unnamed, should be held liable for the acts and omissions complained of. TENTH CLAIM FOR RELIEF Unjust Enrichment (By Plaintiffs 1-310 and 838 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17) 3000. All of the above Paragraphs of this Complaint are hereby incorporated by reference as though fully set forth herein. 3001. Through their conduct as described herein, all Defendants herein were unjustly enriched at the expense of each Plaintiff and by taking his or her money under false pretenses and by ultimately foreclosing or attempting to foreclose upon the homes of the Plaintiffs without legal authority to do so. - 396 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 397 of 414 PagelD #: 1163 3002. To permit the Defendants to retain their unjust gains would be against equity and good conscience, and would ratify the illegal actions taken by the Defendant to the detriment of the Plaintiffs. 3003. Here, in order to avoid the unjust enrichment of the Defendants, each Defendant should be ordered to pay back to each Plaintiff any and all monies unjustly received from him or her. All inclusive, no Plaintiff herein has suffered damages greater than $75,000.00. 3004. Plaintiffs allege that each of the wrongful acts or omissions described above was performed by each Defendant herein, named or unnamed, or was ratified and adopted by each Defendant after its occurrence. Further, those Defendants that did not actively perform the acts or omissions described here did affirmatively aid and abet the other Defendants in the performance of such acts of omissions, before, during or after the fact. 3005. Finally, each Defendant herein, named or unnamed, did knowingly derive some form of profit or benefit from the acts and omissions described herein. All Defendants agreed to work together in the conspiracy and/or joint enterprise described in this paragraph in the manner set forth above. Accordingly, each Defendant, named or unnamed, should be held liable for the acts and omissions complained of. ELEVENTH CLAIM FOR RELIEF Violations of N.Y. Gen. Bus. Law §349 (By Plaintiffs 1-310 against all Defendants; and by Plaintiffs 311-352, 354-673 against all Defendants except 1-4; and by Plaintiff 353 against all Defendants except 1-6; and by Plaintiffs 674-732, 734-803 against all Defendants except 5, 6; and by Plaintiffs 733 against all Defendants except 1-6; and by Plaintiffs 804-837 against all Defendants except 16, 17; - 397 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 398 of 414 PagelD #: 1164 and by Plaintiff 838 against all Defendants except 5) 3006. The allegations in the foregoing paragraphs are repeated and realleged as if fully set forth herein. 3007. Defendants, and each of them, have operated and continue to operate the largest Ponzi scheme in world history with a plan that - at its inception - was intended to, did in fact and continues to the present day to have as its object the theft and conversion of billions of dollars from millions of homeowners, including Plaintiffs. 3008. Defendants' wrongful acts include (but are not limited to) the following: (i) claiming to be servicer of the subject notes at issue herein and demanding monthly loan payments therefor, when in fact no Defendant had or has any legal claim to the monies paid to it by Plaintiffs; (ii) taking loan payments every month from each Plaintiff without crediting any portion of that money to the benefit of any Plaintiff; (iii) promising loan modifications to Plaintiffs while never being an authorized legal representative of any person in a position to actually modify Plaintiffs' loans; (iv) inducing Plaintiffs to default on their loans so that Defendants could profit from the credit default swaps they had purchased, betting that such loans would not be paid as agreed; (v) creating false reasons for charging fees to Plaintiffs based upon nonexistent monies owed, then instituting foreclosure proceedings against Plaintiffs when such fees went unpaid; (vi) issuing wrongful Notices of Default to Plaintiffs; (vii) by refusing to respond, in any way, to Plaintiffs' communications or to communications made for Plaintiffs by their private and public representatives; (viii) converting Plaintiffs' monies as alleged in great detail below, (ix) secreting such acts - 398 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 399 of 414 PagelD #: 1165 of conversion through the massive international network used by defendants to support their Ponzi scheme in violation of law. 3009. The illegal and improper acts of the Defendants have continued, including, inter alia: (i) engaging in the practice of "robo-signing," whereby the lenders used people who had no personal knowledge to sign fraudulent and perjured affidavits that indicated that they had personal knowledge of those matters in an effort to deprive homeowners of their property without due process of law; (ii) refusing to modify loans; and (iii) refusing to entertain short sale opportunities, all with the intention to (a) buy time to further conceal previous conversions and/or (b) convert additional monies from the Plaintiffs in a sum according to proof. 3010. Many of the Plaintiffs were told not to make mortgage payments and/or to sign letters authored by agents of Defendants, exacerbating a desperate financial situation that was either untrue or inflated at Defendants' insistence. 3011. The acts of Defendants constitute deceptive acts and practices in the conduct of Defendants' business, trade and commerce under New York State's General Business Law § 349 ("GBL § 349"), and willfully and knowingly violated this section. 3012. The deceptive acts and practices of the Defendants have had and continue to have a broader impact on consumers at large. 3013. The Plaintiffs relied to their detriment on the deceptive acts and practices of the Defendants. 3014. Pursuant to GBL § 349, Plaintiffs are entitled to an award of reasonable attorney's fees in their favor against Defendants. - 399 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 400 of 414 PagelD #: 1166 3015. Pursuant to GBL § 349, each Plaintiff, individually, is entitled to the statutory maximum in damages. TWELFTH CLAIM FOR RELIEF Civil Racketeering - 18 U.S.C. §1962[c] By All Plaintiffs Against All Defendants 3016. The allegations in the foregoing paragraphs are repeated and realleged as if fully set forth herein. 3017. At all times relevant to this verified First Amended Complaint, and at all times material hereto, all Defendants were "persons" as defined by 18 U.S.C. §1961[3]. 3018. At all times relevant to this verified First Amended Complaint, and at all times material hereto, all Defendants as alleged herein engaged in the operation or management of the Bankster Enterprise, which is an "enterprise" as defined by 18 U.S.C. §1961 [4], the activities of which affect interstate commerce including commerce in the State of New York. 3019. The Bankster Enterprise: [i] is an ongoing association-in-fact, with decision- making framework or mechanism for controlling the association; [ii] has associated members with a common purpose that function as a continuing unit; [iii] is separate and apart from the racketeering activity. 3020. The conduct of the members of the Bankster enterprise, as it relates to the illegal scheme, is for the most part directed by the syndicates referenced in detail in thhe body of this first amended complaint. 3021. This is the structure of the Bankster enterprise as it relates to the "money-in" component of the illegal scheme, as also set forth in body of this complaint. - 400 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 401 of 414 PagelD #: 1167 3022. The Defendants - particularly the loan pools operating under the direction of the Geitner Group — orchestrated the siphoning of the stolen money in direct consultation and association with terrorists, drug cartels, unsourced money entities, and United States Treasury. 3023. All Defendants as members of the Bankster Enterprise are participants in the illegal scheme in different capacities, functions and roles calculated to enrich and expand the Bankster Enterprise so that it could continue to perpetuate the "money-in" and "money-out" components. 3024. The Bankster Enterprise governance occurred through frequent communications among its members by means of interstate and international wire communications via telephone, facsimile, Email, encrypted White House-based and encrypted United States Treasury-based and encrypted United States-Fed-based communications, in interstate and foreign commerce in additional to travel to and from New York and internationally. 3025. The predicate acts form "a pattern of racketeering activity" and are all part of a common criminal plan to perpetuate the illegal scheme and enrich the Bankster enterprise through the Defendants' criminal and fraudulent conduct. 3026. The illegal scam began in January, 2009, and is continuing through and including the current date. 3027. The Defendants have concealed the stolen property and other criminally derived proceeds of the illegal scheme since the dates upon which (a) the banking solvency requirement legally implemented by United States of America on October 19, 1934, had been broken and (b) the TARP program crossed the line of illegality and began - 401 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 402 of 414 PagelD #: 1168 being utilized for personal profit during the first quarter of 2009. This concealment has continued unabated and in the face of reports by the FDIC, the Comptroller of the Currency, the Office the Thrift and the United States Department of Homeland Security and the Report of the Inspector General of the TARP program, in the only manner in which such concealment could continue in the face of contrary reports by the government: Through lies told directly from the mouths of the Defendants and the President of the United States (including on October 3, 2012 during a Presidential Debate). (Hereinafter "The Big Lie.") The Big Lie is the cornerstone of the entire Bankster enterprise and has been repeated by the Obama media in order to misrepresent the true facts to the citizens of the United States and their elected representatives. 3028. All of the predicate acts relate to one another because they represent a common scheme to further the illegal scheme and thus enrich the Defendants and their Bankster enterprise. 3029. The predicate acts progressed in a logical fashion as the illegal scheme expanded from its core in New York, New York, as it fed off monies advanced to it by drug cartels, terrorists, Plaintiffs, American citizens and ultimately the Defendants raid of the fed through bailouts, TARP programs and midnight money printing exercises at the Fed with all Defendants herein assuring that the official Obama administration would have plausible deniability. 3030. Each transfer during this nearly 5-year period constitutes repeated and related predicate acts of . . . [i] money laundering in violation of 18 U.S.C. §1956; [ii] engaging in monetary transactions in property derived from specific unlawful activity - 402 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 403 of 414 PagelD #: 1169 in violation of 18 U.S.C. §1957; [iii] wire fraud in violation of 18 U.S.C. §1343; [iv] financial institution fraud in violation of 18 U.S.C. §1344; [v] mail fraud in violation of 18 U.S.C. §1341; and/or [vi] interstate or international travel in violation of the travel act, 18 U.S.C. §1952. 3031. The ponzi/RICO scheme would not have continued absent the influx of more than $43 trillion ($43,000,000,000,000.00) provided by the Defendants' illegal schemes involving the Fed as set forth in detail above, as well as their money laundering and drug cartel influxes of money also alleged above. The effect of the collapse of the foregoing money laundering and racketeering schemes, is a matter of public record and a fact of which this court can take judicial notice including the recent Senate Report on the money laundering and drug cartel activities of HSBC and resulting admission by Defendant Holder in his official capacity that such unlawfully money laundering activities has spread to all banking institutions in the United States, including at least 1,500 Defendants in this case (e.g., Citigroup, Bank of America and their offshore haven defendants). 3032. Defendants used and exploited U.S. Financial institutions, lawyers and accountants in New York, as well as interstate and international telephone, facsimile, Email, wire transfer and encrypted White House and Fed communications from no later than 2009 until the present. 3033. The activities of the Bankster enterprise directly affected U.S. interstate and foreign commerce through the illegal scheme. 3034. As a direct and proximate result of the violations set forth above, Plaintiffs (including, but not limited to, involuntary plaintiffs) have been injured in their - 403 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 404 of 414 PagelD #: 1170 business, property and in their homes and such injury is continuing. The Defendants' violations of 18 U.S.C. §1962[c] are the proximate cause of these losses. Under the provisions of 18 U.S.C. §1964[c], Plaintiffs are entitled to bring this action and recover herein treble damages, the cost of bringing this suit, prejudgment interest, and recoverable attorneys' fees. Plaintiffs are also entitled to the appointment of a receiver to recover the $43 trillion ($43,000,000,000,000.00) and the fruits of the frauds, parallel injunctive relief and an order that the Defendants and their transferees (wherever located) disgorge and forfeit all of such monies and the fruits of their fraud. 3035. Plaintiffs seek further an order halting the foreclosure of all real estate in the United States of America by any of the Defendants, until the full restitution and disgorgement has occurred in favor of Plaintiffs and against the Banksters, which includes injunctions on any post-foreclosure activities throughout the country as well, all of which shall stop all foreclosure activity of any kind in States such as California, Florida, Ohio, Nevada, Colorado, New Hampshire, New York, Iowa, Wisconsin, Michigan and all other states in which the Banksters have continued their "reverse- run-on-the-bank. " 3036. Plaintiffs seek further an emergency Temporary Restraining Order to take effect immediately, and even sua sponte in the event this Court is so-inclined. THIRTEENTH CLAIM FOR RELIEF CIVIL RACKETEERING - 18 U.S.C. Sec. 1962(d) By All Plaintiffs Against All Defendants - 404 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 405 of 414 PagelD #: 1171 3037. The allegations in the foregoing paragraphs are repeated and realleged as if fully set forth herein 3038. The Defendants entered into a series of agreements between and among each other to engage in a conspiracy to violate 18 U.S.C. Sec. 1962(c). Each Defendant entered into at least one agreement with at least one other Defendant to join the conspiracy, took acts in the furtherance of the conspiracy and knowingly participated in the conspiracy. 3039. The Defendants agreed and conspired to violate 18 U.S.C. 1962(c) by participating, directly or indirectly, in the conduct of the affairs of the Banksters Enterprise through a pattern of racketeering activity, including an agreement that the conspirators, or one of them, would commit or cause the commission of two or more racketeering acts constituting such a pattern. 3040. By engaging in the overt acts and other conduct alleged herein, Defendants have agreed to conspire and did so conspire in violation of 18 U.S.C. 1962(d) to engage in illegal predicate acts that formed a pattern of racketeering activity as defined by 18 U.S.C. 1961(5) and otherwise agreed to violate 18 U.S.C. 1962(c). 3041. Each Defendant is a member of the Bankster Enterprise and hence each conspired to perpetrate the illegal scheme. As co-conspirators, the Defendants are liable for all of the actions committed by all of the co-conspirators within the conspiracy and are liable for all the damages sustained by the Plaintiffs that were caused by any members of the conspiracy, regardless of whether the Defendants were themselves directly involved in a particular aspect of the Banksters Enterprise. - 405 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 406 of 414 PagelD #: 1172 3042. As a direct and proximate result of the violations set forth above, the Plaintiffs have been injured in their business, property, and home. The Defendants' violations of 18 U.S.C. 1962(d) are the proximate cause of these losses. Under the provisions of 18 U.S.C. 1964(c), Plaintiffs are entitled to bring this action and recover herein treble damages, the cost of bringing this suit, prejudgment interest, and recoverable attorney fees. FOURTEENTH CLAIM FOR RELIEF CIVIL RACKETEERING - 18 U.S.C. 1962(c), 1503 By All Plaintiffs Against Defendants Joseph Lawrence Dunn, Dannielle A. Lee, Thomas Layton, Kamala Harris, Maya West, Tony West, Peter Krause, Joseph Crudo, Jr., Joseph Crudo, Sr., Michael Brosnan, Bank of America, and Citigroup. 3043. The allegations in the foregoing paragraphs are repeated and realleged as if fully set forth herein. 3044. At all times relevant to this verified First Amended Complaint, and at all times material hereto, all Defendants were "persons" as defined by 18 U.S.C. § 1961 [3]. 3045. At all times relevant to this verified First Amended Complaint, and at all times material hereto, all Defendants as alleged herein engaged in the operation or management of the Bankster Enterprise, which is an "enterprise" as defined by 18 U.S.C. §1961 [4], the activities of which affect interstate commerce including commerce in the State of New York. 3046. The Bankster Enterprise: [i] is an ongoing association-in-fact, with decision- making framework or mechanism for controlling the association; [ii] has associated members with a common purpose that function as a continuing unit; [iii] is separate and apart from the racketeering activity. - 406 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 407 of 414 PagelD #: 1173 3047. The conduct of the members of the Bankster enterprise, as it relates to the illegal scheme, is for the most part directed by the syndicates referenced in detail in the body of this first amended complaint. 3048. This is the structure of the Bankster enterprise as it relates to the "money-in" component of the illegal scheme, as also set forth in Section BLANK. 3049. BLANK orchestrated the siphoning of the stolen money in direct consultation and association with terrorists, drug cartels, unsourced money entities, and United States Treasury. 3050. All Defendants as members of the Bankster Enterprise are participants in the illegal scheme in different capacities, functions and roles calculated to enrich and expand the Bankster Enterprise so that it could continue to perpetuate the "money-in" and "money-out" components. 3051. The Bankster Enterprise governance occurred through frequent communications among its members by means of interstate and international wire communications via telephone, facsimile, Email, encrypted White House-based and encrypted United States Treasury-based and encrypted United States-Fed-based communications, in interstate and foreign commerce in additional to travel to and from New York and internationally. 3052. The predicate acts form "a pattern of racketeering activity" and are all part of a common criminal plan to perpetuate the illegal scheme and enrich the Bankster enterprise through the Defendants' criminal and fraudulent conduct. 3053. The illegal scam began in January, 2009, and is continuing through and including the current date. - 407 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 408 of 414 PagelD #: 1174 3054. The Defendants have concealed the stolen property and other criminally derived proceeds of the illegal scheme since the dates upon which (a) the banking solvency requirement legally implemented by United States of America on October 19, 1934, had been broken and (b) the TARP program crossed the line of illegality and began being utilized for personal profit during the first quarter of 2009. This concealment has continued unabated and in the face of reports by the FDIC, the Comptroller of the Currency, the Office the Thrift and the United States Department of Homeland Security and the Report of the Inspector General of the TARP program, in the only manner in which such concealment could continue in the face of contrary reports by the government: Through lies told directly from the mouths of the Defendants and the President of the United States (including on October 3, 2012 during a Presidential Debate). (Hereinafter "The Big Lie.") The Big Lie is the cornerstone of the entire Bankster enterprise and has been repeated by the Obama media in order to misrepresent the true facts to the citizens of the United States and their elected representatives. 3055. As American citizens have become knowledgeable of the foregoing scheme, the Defendants - and each of them - have engaged in obstruction of justice, extrinsic fraud, suborning perjury, witness tampering, violations of State and Federal law, other acts chronicled as wrongful by the Office of the Inspector General of the Securities and Exchange Commission, intentional theft, destruction and misuse of American-made revolutionary technology in order to cover-up the conspiracy and without regard to the jobs, billions of dollars of Treasury money and financial benefits they were giving up. - 408 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 409 of 414 PagelD #: 1175 3056. All of the predicate acts relate to one another because they represent a common scheme to further the illegal scheme and thus enrich the Defendants and their Bankster enterprise. 3057. The predicate acts progressed in a logical fashion as the illegal scheme expanded from its core in New York, New York, as it fed off monies advanced to it by drug cartels, terrorists, Plaintiffs, American citizens and ultimately the Defendants raid of the fed through bailouts, TARP programs and midnight money printing exercises at the Fed with all Defendants herein assuring that the official Obama administration would have plausible deniability through utilization of the foregoing fraudulent techniques often used by persons in power to corruptly stop enemies from exposing the truth. 3058. Each act of obstruction of justice and witness tampering set forth above was coupled with unlawful searches and seizures, and an invasion of the attorney client privilege, so that the obstruction of justice could be effectuated. To the extent money was needed to "persuade" a third party to engage in this misconduct, it was paid for by one of the Syndicates set forth in the body of this complaint as a "cost of doing business:" to wit, Obstruction of Justice and Fabrication of Evidence. These acts, including use of fraudulently conveyed and transferred money constitutes repeated and related predicate acts of . . . [i] money laundering in violation of 18 U.S.C. §1956; [ii] engaging in monetary transactions in property derived from specific unlawful activity in violation of 18 U.S.C. §1957; [iii] wire fraud in violation of 18 U.S.C. §1343; [iv] financial institution fraud in violation of 18 U.S.C. §1344; [v] mail fraud in violation of 18 U.S.C. §1341; and/or [vi] interstate or international travel in - 409 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 410 of 414 PagelD #: 1176 violation of the travel act, 18 U.S.C. §1952. The fact that the objects of the fraud for purposes of this claim for relief were Obstruction of Justice is of no moment and only worsens and increases liability to the Defendants. These facts create additional liability of 18 U.S.C. §1503 3059. The ponzi/RICO scheme would not have continued absent the influx of more than $43 trillion ($43,000,000,000,000.00) provided by the Defendants' illegal schemes involving the Fed as set forth in detail above, as well as their money laundering and drug cartel influxes of money also alleged above. The effect of the collapse of the foregoing money laundering and racketeering schemes, is a matter of public record and a fact of which this court can take judicial notice including the recent Senate Report on the money laundering and drug cartel activities of HSBC and resulting admission by Defendant Holder in his official capacity that such unlawfully money laundering activities has spread to all banking institutions in the United States, including at least 1,500 Defendants in this case (e.g., Citigroup, Bank of America and their offshore haven defendants). 3060. Defendants used and exploited U.S. Financial institutions, lawyers and accountants in New York, as well as interstate and international telephone, facsimile, Email, wire transfer and encrypted White House and Fed communications from no later than 2009 until the present. 3061. The activities of the Bankster enterprise directly affected U.S. interstate and foreign commerce through the illegal scheme and obstruction. 3062. As a direct and proximate result of the violations set forth above, Plaintiffs (including, but not limited to, involuntary plaintiffs) have been injured in their - 410 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 411 of 414 PagelD #: 1177 business, property and in their homes and such injury is continuing. The Defendants' violations of 18 U.S.C. §1962[c] and 1503 are the proximate cause of these losses. Under the provisions of 18 U.S.C. §1964[c], Plaintiffs are entitled to bring this action and recover herein treble damages, the cost of bringing this suit, prejudgment interest, and recoverable attorneys' fees. Plaintiffs are also entitled to the appointment of a receiver to recover the $43 trillion ($43,000,000,000,000.00) and the fruits of the frauds, parallel injunctive relief and an order that the Defendants and their transferees (wherever located) disgorge and forfeit all of such monies and the fruits of their fraud. 3063. Plaintiffs seek further an order halting the foreclosure of all real estate in the United States of America by any of the Defendants, until the full restitution and disgorgement has occurred in favor of Plaintiffs and against the Banksters, which includes injunctions on any post-foreclosure activities throughout the country as well, all of which shall stop all foreclosure activity of any kind in States such as California, Florida, Ohio, Nevada, Colorado, New Hampshire, New York, Iowa, Wisconsin, Michigan and all other states in which the Banksters have continued their "reverse- run-on-the-bank. " 3064. Plaintiffs seek further an emergency Temporary Restraining Order to take effect immediately, and even sua sponte in the event this Court is so-inclined. FIFTEENTH CLAIM FOR RELIEF - DECLARATORY RELIEF CONSTITUTIONALITY -- THAT DODD-FRANK LEGISLATION AND ITS APPLICATION IS VIOLATIVE OF THE FOURTEENTH AMENDMENT TO THE UNITED STATES CONSTITUTION AS APPLYING LAWS UNEQUALLY AND EXCLUDING FROM ITS AMBIT BANKS "TOO BIG TO FAIL" AS SUCH BANKS ARE PROTECTED BY THE DODD-FRANK LEGISLATION - 411 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 412 of 414 PagelD #: 1178 3065. The allegations in the foregoing paragraphs are repeated and realleged as if fully set forth herein.] 3066. The Dodd-Frank Legislation purports to prohibit the protection of companies deemed too big to fail. 3067. In fact, the Dodd-Frank Legislation was passed pursuant to the foregoing RICO enterprise to protect - not prevent - entities deemed too big to fail. 3068. The application of the Dodd-Frank Legislation represents an intentional fraud by all Defendants herein, against all Plaintiffs, the American people and involuntary plaintiffs the United States of America and State of New York by perpetuating the ponzi and RICO money laundering schemes set forth above. 3069. Accordingly, the Dodd-Frank Legislation is either unconstitutional on its face, or is unconstitutional as it has been applied. 3070. This Court should enjoin any further activity under the Dodd-Frank Legislation, until the Court- Appointed-Receiver requested herein has issued appropriate reports to this Court on same. DEMAND FOR RELIEF WHEREFORE, Plaintiffs pray for judgment against Defendants, jointly and severally, and each of them as follows and as set forth in each cause of action: - 412 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 413 of 414 PagelD #: 1179 1. General and special damages according to proof, as set forth in the applicable causes of action against defendants named therein, in the sum of at least $73 trillion ($73,000,000,000,000.00); 2. Punitive damages according to proof, as set forth in the applicable causes of action against defendants named therein; 3. Treble damages according to proof, as set forth in the applicable causes of action against defendants named therein; 4. Statutory relief under the specific statutes cited above as set forth in the applicable causes of action against defendants named therein; 5. Restitutional damages according to proof as set forth in the applicable causes of action against defendants named therein; 6. Pre- and post-judgment interest as set forth in the applicable causes of action against defendants named therein; 7. Attorney fees as authorized and provided for by statute, contract or otherwise; and 8. For the appointment of a receiver and injunctive relief as this Court deems appropriate under the applicable causes of action against defendants named therein; 9. For declaratory relief that the Dodd Frank legislation as applied is wrongful and unconstitutional as a matter of law, violative of the New York constitution and subject to injunctive relief immediately as set forth herein. 10. On all causes of action, for such other and further relief as this Court may deem just and proper, - 413 - VERIFIED FIRST AMENDED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF AND THE APPOINTMENT OF A RECEIVER Case l:12-cv-04269-JBW-RML Document 36 Filed 10/25/12 Page 414 of 414 PagelD #: 1180 Dated: October 25, 2012 Respectfully submitted, SPIRE LAW GROUP, LLP By:_ JAMES N. FIEDLER naging Partner 'roJUe-Uuw Application Pending Nicholas M. Moccia Law Office of Nicholas M. Moccia, P.C. Local Counsel 45 Page Avenue Staten Island New York 10309 (718) 701-5772 Case l:12-cv-04269-JBW-RML Document 36-1 Filed 10/25/12 Page 1 of 2 PagelD #: 1181 8. 9. in. Dated: Aitomey fees as authorized and provided for by statute, contract or otherwise; and For the appointment of a receiver and injunctive relief as this Court deems appropriate under the applicable causes of action against defendants named therein: For declaratory relief that the Dodd Frank legislation as applied is wrongful and unconstitutional as a matter of law. violative of the New York constitution and subject to injunctive relief immediately as set forth herein. On all causes of action, for such other and further relief as this Court may deem just and proper, October 25. 2012 Respectfully submitted. SI'IRF LAW GROUP. LLP JAMLS N. FlliDLLK Managing Partner Pro Ifac Vice Application Pending Case l:12-cv-04269-JBW-RML Document 36-1 Filed 10/25/12 Page 2 of 2 PagelD #: 1182 VERIFICATION I Tracey Stein declare: 1. I have personal knowledge of the following facts and am competent to testify regarding all such facts based upon my personal knowledge. 2. lama plaintiff in the above referenced action. 3. The foregoing complaint is true and correct, except as to matters stated on information belief and as to those I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: October 25, 2012 TRACEY STEIN Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 1 of 157 PagelD #: 1183 EXHIBIT "A Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 2 of 157 PagelD #: 1184 DEFENDANT NO. 151 THROUGH DEFENDANT NO. 1808 "New York Loan Pools" 43. Defendant ALTERNATIVE LOAN TRUST 2004- 10CB shall be designated as Defendant No. 151. 44. Defendant ALTERNATIVE LOAN TRUST 2004-12CB shall be designated as Defendant No. 152. 45. Defendant ALTERNATIVE LOAN TRUST 2004- 13CB shall be designated as Defendant No. 153. 46. Defendant ALTERNATIVE LOAN TRUST 2004-14T2 shall be designated as Defendant No. 154. 47. Defendant ALTERNATIVE LOAN TRUST 2004-15 shall be designated as Defendant No. 155. 48. Defendant ALTERNATIVE LOAN TRUST 2004-16CB shall be designated as Defendant No. 156. 49. Defendant ALTERNATIVE LOAN TRUST 2004- 17CB shall be designated as Defendant No. 157. 50. Defendant ALTERNATIVE LOAN TRUST 2004- 18CB shall be designated as Defendant No. 158. 51. Defendant ALTERNATIVE LOAN TRUST 2004-20T1 shall be designated as Defendant No. 159. 52. Defendant ALTERNATIVE LOAN TRUST 2004-22CB shall be designated as Defendant No. 160. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 3 of 157 PagelD #: 1185 53. Defendant ALTERNATIVE LOAN TRUST 2004-24CB shall be designated as Defendant No. 161. 54. Defendant ALTERNATIVE LOAN TRUST 2004-25CB shall be designated as Defendant No. 162. 55. Defendant ALTERNATIVE LOAN TRUST 2004-26T1 shall be designated as Defendant No. 163. 56. Defendant ALTERNATIVE LOAN TRUST 2004-27CB shall be designated as Defendant No. 164. 57. Defendant ALTERNATIVE LOAN TRUST 2004-7T1 shall be designated as Defendant No. 165. 58. Defendant ALTERNATIVE LOAN TRUST 2004-8CB shall be designated as Defendant No. 166. 59. Defendant ALTERNATIVE LOAN TRUST 2004-9T1 shall be designated as Defendant No. 167. 60. Defendant ALTERNATIVE LOAN TRUST 2004-J7 shall be designated as Defendant No. 168. 61. Defendant ALTERNATIVE LOAN TRUST 2004- J8 shall be designated as Defendant No. 169. 62. Defendant ALTERNATIVE LOAN TRUST 2004-J9 shall be designated as Defendant No. 170. 63. Defendant ALTERNATIVE LOAN TRUST 2005- 10CB shall be designated as Defendant No. 171. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 4 of 157 PagelD #: 1186 64. Defendant ALTERNATIVE LOAN TRUST 2005-1 1CB shall be designated as Defendant No. 172. 65. Defendant ALTERNATIVE LOAN TRUST 2005-13CB shall be designated as Defendant No. 173. 66. Defendant ALTERNATIVE LOAN TRUST 2005-14 shall be designated as Defendant No. 174. 67. Defendant ALTERNATIVE LOAN TRUST 2005-16 shall be designated as Defendant No. 175. 68. Defendant ALTERNATIVE LOAN TRUST 2005-17 shall be designated as Defendant No. 176. 69. Defendant ALTERNATIVE LOAN TRUST 2005-18CB shall be designated as Defendant No. 177. 70. Defendant ALTERNATIVE LOAN TRUST 2005-19CB shall be designated as Defendant No. 178. 71. Defendant ALTERNATIVE LOAN TRUST 2005-20CB shall be designated as Defendant No. 179. 72. Defendant ALTERNATIVE LOAN TRUST 2005-2 1CB shall be designated as Defendant No. 180. 73. Defendant ALTERNATIVE LOAN TRUST 2005-22T1 shall be designated as Defendant No. 181. 74. Defendant ALTERNATIVE LOAN TRUST 2005-23CB shall be designated as Defendant No. 182. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 5 of 157 PagelD #: 1187 75. Defendant ALTERNATIVE LOAN TRUST 2005-24 shall be designated as Defendant No. 183. 76. Defendant ALTERNATIVE LOAN TRUST 2005-25T1 shall be designated as Defendant No. 184. 77. Defendant ALTERNATIVE LOAN TRUST 2005-26CB shall be designated as Defendant No. 185. 78. Defendant ALTERNATIVE LOAN TRUST 2005-27 shall be designated as Defendant No. 186. 79. Defendant ALTERNATIVE LOAN TRUST 2005-28CB shall be designated as Defendant No. 187. 80. Defendant ALTERNATIVE LOAN TRUST 2005-29CB shall be designated as Defendant No. 188. 81. Defendant ALTERNATIVE LOAN TRUST 2005-30CB shall be designated as Defendant No. 189. 82. Defendant ALTERNATIVE LOAN TRUST 2005-31 shall be designated as Defendant No. 190. 83. Defendant ALTERNATIVE LOAN TRUST 2005-32T1 shall be designated as Defendant No. 191. 84. Defendant ALTERNATIVE LOAN TRUST 2005-33CB shall be designated as Defendant No. 192. 85. Defendant ALTERNATIVE LOAN TRUST 2005-34CB shall be designated as Defendant No. 193. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 6 of 157 PagelD #: 1188 86. Defendant ALTERNATIVE LOAN TRUST 2005-35CB shall be designated as Defendant No. 194. 87. Defendant ALTERNATIVE LOAN TRUST 2005-36 shall be designated as Defendant No. 195. 88. Defendant ALTERNATIVE LOAN TRUST 2005-37T1 shall be designated as Defendant No. 196. 89. Defendant ALTERNATIVE LOAN TRUST 2005-38 shall be designated as Defendant No. 197. 90. Defendant ALTERNATIVE LOAN TRUST 2005-4 shall be designated as Defendant No. 198. 91. Defendant ALTERNATIVE LOAN TRUST 2005-40CB shall be designated as Defendant No. 199. 92. Defendant ALTERNATIVE LOAN TRUST 2005-41 shall be designated as Defendant No. 200. 93. Defendant ALTERNATIVE LOAN TRUST 2005-42CB shall be designated as Defendant No. 201. 94. Defendant ALTERNATIVE LOAN TRUST 2005-43 shall be designated as Defendant No. 202. 95. Defendant ALTERNATIVE LOAN TRUST 2005-44 shall be designated as Defendant No. 203. 96. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 204. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 7 of 157 PagelD #: 1189 97. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 205. 98. Defendant ALTERNATIVE LOAN TRUST 2005-45 shall be designated as Defendant No. 206. 99. Defendant ALTERNATIVE LOAN TRUST 2005-46CB shall be designated as Defendant No. 207. 100. Defendant ALTERNATIVE LOAN TRUST 2005-47CB shall be designated as Defendant No. 208. 101. Defendant ALTERNATIVE LOAN TRUST 2005-48T1 shall be designated as Defendant No. 209. 102. Defendant ALTERNATIVE LOAN TRUST 2005-49CB shall be designated as Defendant No. 210. 103. Defendant ALTERNATIVE LOAN TRUST 2005-50CB shall be designated as Defendant No. 211. 104. Defendant ALTERNATIVE LOAN TRUST 2005-51 shall be designated as Defendant No. 212. 105. Defendant ALTERNATIVE LOAN TRUST 2005-53T2 shall be designated as Defendant No. 213. 106. Defendant ALTERNATIVE LOAN TRUST 2005-54CB shall be designated as Defendant No. 214. 107. Defendant ALTERNATIVE LOAN TRUST 2005-55CB shall be designated as Defendant No. 215. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 8 of 157 PagelD #: 1190 108. Defendant ALTERNATIVE LOAN TRUST 2005-56 shall be designated as Defendant No. 216. 109. Defendant ALTERNATIVE LOAN TRUST 2005-56 shall be designated as Defendant No. 217. 110. Defendant ALTERNATIVE LOAN TRUST 2005-57CB shall be designated as Defendant No. 218. 111. Defendant ALTERNATIVE LOAN TRUST 2005-58 shall be designated as Defendant No. 219. 112. Defendant ALTERNATIVE LOAN TRUST 2005-59 shall be designated as Defendant No. 220. 113. Defendant ALTERNATIVE LOAN TRUST 2005-60T1 shall be designated as Defendant No. 221. 114. Defendant ALTERNATIVE LOAN TRUST 2005-61 shall be designated as Defendant No. 222. 115. Defendant ALTERNATIVE LOAN TRUST 2005-62 shall be designated as Defendant No. 223. 116. Defendant ALTERNATIVE LOAN TRUST 2005-63 shall be designated as Defendant No. 224. 117. Defendant ALTERNATIVE LOAN TRUST 2005-64CB shall be designated as Defendant No. 225. 118. Defendant ALTERNATIVE LOAN TRUST 2005-65CB shall be designated as Defendant No. 226. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 9 of 157 PagelD #: 1191 119. Defendant ALTERNATIVE LOAN TRUST 2005-6CB shall be designated as Defendant No. 227. 120. Defendant ALTERNATIVE LOAN TRUST 2005-70CB shall be designated as Defendant No. 228. 121. Defendant ALTERNATIVE LOAN TRUST 2005-71 shall be designated as Defendant No. 229. 122. Defendant ALTERNATIVE LOAN TRUST 2005-74T1 shall be designated as Defendant No. 230. 123. Defendant ALTERNATIVE LOAN TRUST 2005-75CB shall be designated as Defendant No. 231. 124. Defendant ALTERNATIVE LOAN TRUST 2005-75CB shall be designated as Defendant No. 232. 125. Defendant ALTERNATIVE LOAN TRUST 2005-76 shall be designated as Defendant No. 233. 126. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 234. 127. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 235. 128. Defendant ALTERNATIVE LOAN TRUST 2005-77T1 shall be designated as Defendant No. 236. 129. Defendant ALTERNATIVE LOAN TRUST 2005-79CB shall be designated as Defendant No. 237. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 10 of 157 PagelD #: 1192 130. Defendant ALTERNATIVE LOAN TRUST 2005-7CB shall be designated as Defendant No. 238. 131. Defendant ALTERNATIVE LOAN TRUST 2005-80CB shall be designated as Defendant No. 239. 132. Defendant ALTERNATIVE LOAN TRUST 2005-81 shall be designated as Defendant No. 240. 133. Defendant ALTERNATIVE LOAN TRUST 2005-82 shall be designated as Defendant No. 241. 134. Defendant ALTERNATIVE LOAN TRUST 2005-82 shall be designated as Defendant No. 242. 135. Defendant ALTERNATIVE LOAN TRUST 2005-83CB shall be designated as Defendant No. 243. 136. Defendant ALTERNATIVE LOAN TRUST 2005-84 shall be designated as Defendant No. 244. 137. Defendant ALTERNATIVE LOAN TRUST 2005-85CB shall be designated as Defendant No. 245. 138. Defendant ALTERNATIVE LOAN TRUST 2005-86CB shall be designated as Defendant No. 246. 139. Defendant ALTERNATIVE LOAN TRUST 2005-9CB shall be designated as Defendant No. 247. 140. Defendant ALTERNATIVE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 248. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 11 of 157 PagelD #: 1193 141. Defendant ALTERNATIVE LOAN TRUST 2005-IM1 shall be designated as Defendant No. 249. 142. Defendant ALTERNATIVE LOAN TRUST 2005-J10 shall be designated as Defendant No. 250. 143. Defendant ALTERNATIVE LOAN TRUST 2005-J11 shall be designated as Defendant No. 251. 144. Defendant ALTERNATIVE LOAN TRUST 2005-J11 shall be designated as Defendant No. 252. 145. Defendant ALTERNATIVE LOAN TRUST 2005-J4 shall be designated as Defendant No. 253. 146. Defendant ALTERNATIVE LOAN TRUST 2005-J6 shall be designated as Defendant No. 254. 147. Defendant ALTERNATIVE LOAN TRUST 2005-J7 shall be designated as Defendant No. 255. 148. Defendant ALTERNATIVE LOAN TRUST 2006-0C5 shall be designated as Defendant No. 256. 149. Defendant ALTERNATIVE LOAN TRUST 2006-1 1CB shall be designated as Defendant No. 257. 150. Defendant ALTERNATIVE LOAN TRUST 2006-12CB shall be designated as Defendant No. 258. 151. Defendant ALTERNATIVE LOAN TRUST 2006-13T1 shall be designated as Defendant No. 259. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 12 of 157 PagelD #: 1194 152. Defendant ALTERNATIVE LOAN TRUST 2006-14CB shall be designated as Defendant No. 260. 153. Defendant ALTERNATIVE LOAN TRUST 2006-15CB shall be designated as Defendant No. 261. 154. Defendant ALTERNATIVE LOAN TRUST 2006-16CB shall be designated as Defendant No. 262. 155. Defendant ALTERNATIVE LOAN TRUST 2006-17T1 shall be designated as Defendant No. 263. 156. Defendant ALTERNATIVE LOAN TRUST 2006-1 8CB shall be designated as Defendant No. 264. 157. Defendant ALTERNATIVE LOAN TRUST 2006-19CB shall be designated as Defendant No. 265. 158. Defendant ALTERNATIVE LOAN TRUST 2006-20CB shall be designated as Defendant No. 266. 159. Defendant ALTERNATIVE LOAN TRUST 2006-2 1CB shall be designated as Defendant No. 267. 160. Defendant ALTERNATIVE LOAN TRUST 2006-2 1CB shall be designated as Defendant No. 268. 161. Defendant ALTERNATIVE LOAN TRUST 2006-2 1CB shall be designated as Defendant No. 269. 162. Defendant ALTERNATIVE LOAN TRUST 2006-23CB shall be designated as Defendant No. 270. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 13 of 157 PagelD #: 1195 163. Defendant ALTERNATIVE LOAN TRUST 2006-23CB shall be designated as Defendant No. 271. 164. Defendant ALTERNATIVE LOAN TRUST 2006-24CB shall be designated as Defendant No. 272. 165. Defendant ALTERNATIVE LOAN TRUST 2006-25CB shall be designated as Defendant No. 273. 166. Defendant ALTERNATIVE LOAN TRUST 2006-25CB shall be designated as Defendant No. 274. 167. Defendant ALTERNATIVE LOAN TRUST 2006-26CB shall be designated as Defendant No. 275. 168. Defendant ALTERNATIVE LOAN TRUST 2006-26CB shall be designated as Defendant No. 276. 169. Defendant ALTERNATIVE LOAN TRUST 2006-27CB shall be designated as Defendant No. 277. 170. Defendant ALTERNATIVE LOAN TRUST 2006-28CB shall be designated as Defendant No. 278. 171. Defendant ALTERNATIVE LOAN TRUST 2006-29T1 shall be designated as Defendant No. 279. 172. Defendant ALTERNATIVE LOAN TRUST 2006-2CB shall be designated as Defendant No. 280. 173. Defendant ALTERNATIVE LOAN TRUST 2006-30T1 shall be designated as Defendant No. 281. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 14 of 157 PagelD #: 1196 174. Defendant ALTERNATIVE LOAN TRUST 2006-3 1CB shall be designated as Defendant No. 282. 175. Defendant ALTERNATIVE LOAN TRUST 2006-3 1CB shall be designated as Defendant No. 283. 176. Defendant ALTERNATIVE LOAN TRUST 2006-32CB shall be designated as Defendant No. 284. 177. Defendant ALTERNATIVE LOAN TRUST 2006-33CB shall be designated as Defendant No. 285. 178. Defendant ALTERNATIVE LOAN TRUST 2006-34 shall be designated as Defendant No. 286. 179. Defendant ALTERNATIVE LOAN TRUST 2006-35CB shall be designated as Defendant No. 287. 180. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 288. 181. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 289. 182. Defendant ALTERNATIVE LOAN TRUST 2006-36T2 shall be designated as Defendant No. 290. 183. Defendant ALTERNATIVE LOAN TRUST 2006-37R shall be designated as Defendant No. 291. 184. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 292. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 15 of 157 PagelD #: 1197 185. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 293. 186. Defendant ALTERNATIVE LOAN TRUST 2006-39CB shall be designated as Defendant No. 294. 187. Defendant ALTERNATIVE LOAN TRUST 2006-40T1 shall be designated as Defendant No. 295. 188. Defendant ALTERNATIVE LOAN TRUST 2006-40T1 shall be designated as Defendant No. 296. 189. Defendant ALTERNATIVE LOAN TRUST 2006-4 1CB shall be designated as Defendant No. 297. 190. Defendant ALTERNATIVE LOAN TRUST 2006-42 shall be designated as Defendant No. 298. 191. Defendant ALTERNATIVE LOAN TRUST 2006-43CB shall be designated as Defendant No. 299. 192. Defendant ALTERNATIVE LOAN TRUST 2006-45T1 shall be designated as Defendant No. 300. 193. Defendant ALTERNATIVE LOAN TRUST 2006-45T1 shall be designated as Defendant No. 301. 194. Defendant ALTERNATIVE LOAN TRUST 2006-46 shall be designated as Defendant No. 302. 195. Defendant ALTERNATIVE LOAN TRUST 2006-4CB shall be designated as Defendant No. 303. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 16 of 157 PagelD #: 1198 196. Defendant ALTERNATIVE LOAN TRUST 2006-5T2 shall be designated as Defendant No. 304. 197. Defendant ALTERNATIVE LOAN TRUST 2006-6CB shall be designated as Defendant No. 305. 198. Defendant ALTERNATIVE LOAN TRUST 2006-7CB shall be designated as Defendant No. 306. 199. Defendant ALTERNATIVE LOAN TRUST 2006-7CB shall be designated as Defendant No. 307. 200. Defendant ALTERNATIVE LOAN TRUST 2006-8T1 shall be designated as Defendant No. 308. 201. Defendant ALTERNATIVE LOAN TRUST 2006-9T1 shall be designated as Defendant No. 309. 202. Defendant ALTERNATIVE LOAN TRUST 2006-HY10 shall be designated as Defendant No. 310. 203. Defendant ALTERNATIVE LOAN TRUST 2006-HY11 shall be designated as Defendant No. 311. 204. Defendant ALTERNATIVE LOAN TRUST 2006-HY12 shall be designated as Defendant No. 312. 205. Defendant ALTERNATIVE LOAN TRUST 2006-HY12 shall be designated as Defendant No. 313. 206. Defendant ALTERNATIVE LOAN TRUST 2006-HY13 shall be designated as Defendant No. 314. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 17 of 157 PagelD #: 1199 207. Defendant ALTERNATIVE LOAN TRUST 2006-HY3 shall be designated as Defendant No. 315. 208. Defendant ALTERNATIVE LOAN TRUST 2006-J1 shall be designated as Defendant No. 316. 209. Defendant ALTERNATIVE LOAN TRUST 2006-J2 shall be designated as Defendant No. 317. 210. Defendant ALTERNATIVE LOAN TRUST 2006-J2 shall be designated as Defendant No. 318. 211. Defendant ALTERNATIVE LOAN TRUST 2006-J3 shall be designated as Defendant No. 319. 212. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 320. 213. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 321. 214. Defendant ALTERNATIVE LOAN TRUST 2006-J4 shall be designated as Defendant No. 322. 215. Defendant ALTERNATIVE LOAN TRUST 2006-J5 shall be designated as Defendant No. 323. 216. Defendant ALTERNATIVE LOAN TRUST 2006-J6 shall be designated as Defendant No. 324. 217. Defendant ALTERNATIVE LOAN TRUST 2006-J7 shall be designated as Defendant No. 325. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 18 of 157 PagelD #: 1200 218. Defendant ALTERNATIVE LOAN TRUST 2006-J8 shall be designated as Defendant No. 326. 219. Defendant ALTERNATIVE LOAN TRUST 2006-J8 shall be designated as Defendant No. 327. 220. Defendant ALTERNATIVE LOAN TRUST 2006-OA1 shall be designated as Defendant No. 328. 221. Defendant ALTERNATIVE LOAN TRUST 2006-OA10 shall be designated as Defendant No. 329. 222. Defendant ALTERNATIVE LOAN TRUST 2006-OA10 shall be designated as Defendant No. 330. 223. Defendant ALTERNATIVE LOAN TRUST 2006-OA11 shall be designated as Defendant No. 331. 224. Defendant ALTERNATIVE LOAN TRUST 2006-OA12 shall be designated as Defendant No. 332. 225. Defendant ALTERNATIVE LOAN TRUST 2006-OA14 shall be designated as Defendant No. 333. 226. Defendant ALTERNATIVE LOAN TRUST 2006-OA16 shall be designated as Defendant No. 334. 227. Defendant ALTERNATIVE LOAN TRUST 2006-OA17 shall be designated as Defendant No. 335. 228. Defendant ALTERNATIVE LOAN TRUST 2006-OA18 shall be designated as Defendant No. 336. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 19 of 157 PagelD #: 1201 229. Defendant ALTERNATIVE LOAN TRUST 2006-OA19 shall be designated as Defendant No. 337. 230. Defendant ALTERNATIVE LOAN TRUST 2006-OA2 shall be designated as Defendant No. 338. 231. Defendant ALTERNATIVE LOAN TRUST 2006-OA21 shall be designated as Defendant No. 339. 232. Defendant ALTERNATIVE LOAN TRUST 2006-OA21 shall be designated as Defendant No. 340. 233. Defendant ALTERNATIVE LOAN TRUST 2006-OA22 shall be designated as Defendant No. 341. 234. Defendant ALTERNATIVE LOAN TRUST 2006-OA3 shall be designated as Defendant No. 342. 235. Defendant ALTERNATIVE LOAN TRUST 2006-OA6 shall be designated as Defendant No. 343. 236. Defendant ALTERNATIVE LOAN TRUST 2006-OA7 shall be designated as Defendant No. 344. 237. Defendant ALTERNATIVE LOAN TRUST 2006-OA7 shall be designated as Defendant No. 345. 238. Defendant ALTERNATIVE LOAN TRUST 2006-OA8 shall be designated as Defendant No. 346. 239. Defendant ALTERNATIVE LOAN TRUST 2006-OA8 shall be designated as Defendant No. 347. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 20 of 157 PagelD #: 1202 240. Defendant ALTERNATIVE LOAN TRUST 2006-OA9 shall be designated as Defendant No. 348. 241. Defendant ALTERNATIVE LOAN TRUST 2006-OC1 shall be designated as Defendant No. 349. 242. Defendant ALTERNATIVE LOAN TRUST 2006-OC1 shall be designated as Defendant No. 350. 243. Defendant ALTERNATIVE LOAN TRUST 2006-OC10 shall be designated as Defendant No. 351. 244. Defendant ALTERNATIVE LOAN TRUST 2006-OC11 shall be designated as Defendant No. 352. 245. Defendant ALTERNATIVE LOAN TRUST 2006-OC2 shall be designated as Defendant No. 353. 246. Defendant ALTERNATIVE LOAN TRUST 2006-OC3 shall be designated as Defendant No. 354. 247. Defendant ALTERNATIVE LOAN TRUST 2006-OC4 shall be designated as Defendant No. 355. 248. Defendant ALTERNATIVE LOAN TRUST 2006-OC6 shall be designated as Defendant No. 356. 249. Defendant ALTERNATIVE LOAN TRUST 2006-OC7 shall be designated as Defendant No. 357. 250. Defendant ALTERNATIVE LOAN TRUST 2006-OC7 shall be designated as Defendant No. 358. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 21 of 157 PagelD #: 1203 251. Defendant ALTERNATIVE LOAN TRUST 2006-OC8 shall be designated as Defendant No. 359. 252. Defendant ALTERNATIVE LOAN TRUST 2006-OC9 shall be designated as Defendant No. 360. 253. Defendant ALTERNATIVE LOAN TRUST 2007-10CB shall be designated as Defendant No. 361. 254. Defendant ALTERNATIVE LOAN TRUST 2007-10CB shall be designated as Defendant No. 362. 255. Defendant ALTERNATIVE LOAN TRUST 2007-10CB shall be designated as Defendant No. 363. 256. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 364. 257. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 365. 258. Defendant ALTERNATIVE LOAN TRUST 2007-1 1T1 shall be designated as Defendant No. 366. 259. Defendant ALTERNATIVE LOAN TRUST 2007-12T1 shall be designated as Defendant No. 367. 260. Defendant ALTERNATIVE LOAN TRUST 2007-12T1 shall be designated as Defendant No. 368. 261. Defendant ALTERNATIVE LOAN TRUST 2007-12T1 shall be designated as Defendant No. 369. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 22 of 157 PagelD #: 1204 262. Defendant ALTERNATIVE LOAN TRUST 2007-13 shall be designated as Defendant No. 370. 263. Defendant ALTERNATIVE LOAN TRUST 2007- 14T2 shall be designated as Defendant No. 371. 264. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 372. 265. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 373. 266. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 374. 267. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 375. 268. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 376. 269. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 377. 270. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 378. 271. Defendant ALTERNATIVE LOAN TRUST 2007-15CB shall be designated as Defendant No. 379. 272. Defendant ALTERNATIVE LOAN TRUST 2007-1 5CB shall be designated as Defendant No. 380. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 23 of 157 PagelD #: 1205 273. Defendant ALTERNATIVE LOAN TRUST 2007- 16CB shall be designated as Defendant No. 381. 274. Defendant ALTERNATIVE LOAN TRUST 2007-16CB shall be designated as Defendant No. 382. 275. Defendant ALTERNATIVE LOAN TRUST 2007- 16CB shall be designated as Defendant No. 383. 276. Defendant ALTERNATIVE LOAN TRUST 2007-17CB shall be designated as Defendant No. 384. 277. Defendant ALTERNATIVE LOAN TRUST 2007-17CB shall be designated as Defendant No. 385. 278. Defendant ALTERNATIVE LOAN TRUST 2007-1 8CB shall be designated as Defendant No. 386. 279. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 387. 280. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 388. 281. Defendant ALTERNATIVE LOAN TRUST 2007-19 shall be designated as Defendant No. 389. 282. Defendant ALTERNATIVE LOAN TRUST 2007-1T1 shall be designated as Defendant No. 390. 283. Defendant ALTERNATIVE LOAN TRUST 2007-20 shall be designated as Defendant No. 391. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 24 of 157 PagelD #: 1206 284. Defendant ALTERNATIVE LOAN TRUST 2007-2 1CB shall be designated as Defendant No. 392. 285. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 393. 286. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 394. 287. Defendant ALTERNATIVE LOAN TRUST 2007-22 shall be designated as Defendant No. 395. 288. Defendant ALTERNATIVE LOAN TRUST 2007-23CB shall be designated as Defendant No. 396. 289. Defendant ALTERNATIVE LOAN TRUST 2007-23CB shall be designated as Defendant No. 397. 290. Defendant ALTERNATIVE LOAN TRUST 2007-24 shall be designated as Defendant No. 398. 291. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 399. 292. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 400. 293. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 401. 294. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 402. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 25 of 157 PagelD #: 1207 295. Defendant ALTERNATIVE LOAN TRUST 2007-25 shall be designated as Defendant No. 403. 296. Defendant ALTERNATIVE LOAN TRUST 2007-2CB shall be designated as Defendant No. 404. 297. Defendant ALTERNATIVE LOAN TRUST 2007-3T1 shall be designated as Defendant No. 405. 298. Defendant ALTERNATIVE LOAN TRUST 2007-3T1 shall be designated as Defendant No. 406. 299. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 407. 300. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 408. 301. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 409. 302. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 410. 303. Defendant ALTERNATIVE LOAN TRUST 2007-4CB shall be designated as Defendant No. 411. 304. Defendant ALTERNATIVE LOAN TRUST 2007-5CB shall be designated as Defendant No. 412. 305. Defendant ALTERNATIVE LOAN TRUST 2007-6 shall be designated as Defendant No. 413. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 26 of 157 PagelD #: 1208 306. Defendant ALTERNATIVE LOAN TRUST 2007-7T2 shall be designated as Defendant No. 414. 307. Defendant ALTERNATIVE LOAN TRUST 2007-7T2 shall be designated as Defendant No. 415. 308. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 416. 309. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 417. 310. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 418. 311. Defendant ALTERNATIVE LOAN TRUST 2007-8CB shall be designated as Defendant No. 419. 312. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 420. 313. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 421. 314. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 422. 315. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 423. 316. Defendant ALTERNATIVE LOAN TRUST 2007-9T1 shall be designated as Defendant No. 424. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 27 of 157 PagelD #: 1209 317. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 425. 318. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 426. 319. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 427. 320. Defendant ALTERNATIVE LOAN TRUST 2007-AL1 shall be designated as Defendant No. 428. 321. Defendant ALTERNATIVE LOAN TRUST 2007-HY2 shall be designated as Defendant No. 429. 322. Defendant ALTERNATIVE LOAN TRUST 2007-HY3 shall be designated as Defendant No. 430. 323. Defendant ALTERNATIVE LOAN TRUST 2007-HY4 shall be designated as Defendant No. 431. 324. Defendant ALTERNATIVE LOAN TRUST 2007-HY5R shall be designated as Defendant No. 432. 325. Defendant ALTERNATIVE LOAN TRUST 2007-HY6 shall be designated as Defendant No. 433. 326. Defendant ALTERNATIVE LOAN TRUST 2007-HY7C shall be designated as Defendant No. 434. 327. Defendant ALTERNATIVE LOAN TRUST 2007-HY8C shall be designated as Defendant No. 435. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 28 of 157 PagelD #: 1210 328. Defendant ALTERNATIVE LOAN TRUST 2007-HY9 shall be designated as Defendant No. 436. 329. Defendant ALTERNATIVE LOAN TRUST 2007-HY9 shall be designated as Defendant No. 437. 330. Defendant ALTERNATIVE LOAN TRUST 2007-J1 shall be designated as Defendant No. 438. 331. Defendant ALTERNATIVE LOAN TRUST 2007-J1 shall be designated as Defendant No. 439. 332. Defendant ALTERNATIVE LOAN TRUST 2007-J1 shall be designated as Defendant No. 440. 333. Defendant ALTERNATIVE LOAN TRUST 2007-J2 shall be designated as Defendant No. 441. 334. Defendant ALTERNATIVE LOAN TRUST 2007-J2 shall be designated as Defendant No. 442. 335. Defendant ALTERNATIVE LOAN TRUST 2007-OA10 shall be designated as Defendant No. 443. 336. Defendant ALTERNATIVE LOAN TRUST 2007-OA1 1 shall be designated as Defendant No. 444. 337. Defendant ALTERNATIVE LOAN TRUST 2007-OA2 shall be designated as Defendant No. 445. 338. Defendant ALTERNATIVE LOAN TRUST 2007-OA3 shall be designated as Defendant No. 446. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 29 of 157 PagelD #: 1211 339. Defendant ALTERNATIVE LOAN TRUST 2007-OA4 shall be designated as Defendant No. 447. 340. Defendant ALTERNATIVE LOAN TRUST 2007-OA6 shall be designated as Defendant No. 448. 341. Defendant ALTERNATIVE LOAN TRUST 2007-OA7 shall be designated as Defendant No. 449. 342. Defendant ALTERNATIVE LOAN TRUST 2007-OA8 shall be designated as Defendant No. 450. 343. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 451. 344. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 452. 345. Defendant ALTERNATIVE LOAN TRUST 2007-OA9 shall be designated as Defendant No. 453. 346. Defendant ALTERNATIVE LOAN TRUST 2007-OH1 shall be designated as Defendant No. 454. 347. Defendant ALTERNATIVE LOAN TRUST 2007-OH1 shall be designated as Defendant No. 455. 348. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 456. 349. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 457. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 30 of 157 PagelD #: 1212 350. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 458. 351. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 459. 352. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 460. 353. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 461. 354. Defendant ALTERNATIVE LOAN TRUST 2007-OH2 shall be designated as Defendant No. 462. 355. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 463. 356. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 464. 357. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 465. 358. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 466. 359. Defendant ALTERNATIVE LOAN TRUST 2007-OH3 shall be designated as Defendant No. 467. 360. Defendant ALTERNATIVE LOAN TRUST MORT PASS THROUGH CERT SERIES 2003-4 shall be designated as Defendant No. 468. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 31 of 157 PagelD #: 1213 361. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2005-12R shall be designated as Defendant No. 469. 362. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2006-22R shall be designated as Defendant No. 470. 363. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2007-26R shall be designated as Defendant No. 471. 364. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-1R shall be designated as Defendant No. 472. 365. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 473. 366. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 474. 367. Defendant ALTERNATIVE LOAN TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 475. 368. Defendant ALTERNATIVE LOAN TRUST SERIES 2003-1 shall be designated as Defendant No. 476. 369. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-3 shall be designated as Defendant No. 477. 370. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-5 shall be designated as Defendant No. 478. 371 . Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2005-12 shall be designated as Defendant No. 479. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 32 of 157 PagelD #: 1214 372. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-1 shall be designated as Defendant No. 480. 373. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-2 shall be designated as Defendant No. 481. 374. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-3 shall be designated as Defendant No. 482. 375. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-4 shall be designated as Defendant No. 483. 376. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5 shall be designated as Defendant No. 484. 377. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-6 shall be designated as Defendant No. 485. 378. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-7 shall be designated as Defendant No. 486. 379. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-8 shall be designated as Defendant No. 487. 380. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-9 shall be designated as Defendant No. 488. 381. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2007-1 shall be designated as Defendant No. 489. 382. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2007-2 shall be designated as Defendant No. 490. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 33 of 157 PagelD #: 1215 383. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-10 shall be designated as Defendant No. 491. 384. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-11 shall be designated as Defendant No. 492. 385. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-12 shall be designated as Defendant No. 493. 386. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-4 shall be designated as Defendant No. 494. 387. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-5 shall be designated as Defendant No. 495. 388. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-6 shall be designated as Defendant No. 496. 389. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-7 shall be designated as Defendant No. 497. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 34 of 157 PagelD #: 1216 390. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-8 shall be designated as Defendant No. 498. 391. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-9 shall be designated as Defendant No. 499. 392. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-1 shall be designated as Defendant No. 500. 393. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-10 shall be designated as Defendant No. 501. 394. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-11 shall be designated as Defendant No. 502. 395. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-2 shall be designated as Defendant No. 503. 396. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-3 shall be designated as Defendant No. 504. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 35 of 157 PagelD #: 1217 397. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-4 shall be designated as Defendant No. 505. 398. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-5 shall be designated as Defendant No. 506. 399. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-6 shall be designated as Defendant No. 507. 400. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-7 shall be designated as Defendant No. 508. 401. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-8 shall be designated as Defendant No. 509. 402. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-9 shall be designated as Defendant No. 510. 403. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2003 1 1 shall be designated as Defendant No. 5 1 1 . 404. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2004 2 shall be designated as Defendant No. 512. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 36 of 157 PagelD #: 1218 405. Defendant BANC OF AMERICA designated as Defendant No. 513. 406. Defendant BANC OF AMERICA designated as Defendant No. 514. 407. Defendant BANC OF AMERICA designated as Defendant No. 515. 408. Defendant BANC OF AMERICA designated as Defendant No. 516. 409. Defendant BANC OF AMERICA designated as Defendant No. 517. 410. Defendant BANC OF AMERICA designated as Defendant No. 518. 411. Defendant BANC OF AMERICA designated as Defendant No. 519. 412. Defendant BANC OF AMERICA designated as Defendant No. 520. 413. Defendant BANC OF AMERICA designated as Defendant No. 521. 414. Defendant BANC OF AMERICA designated as Defendant No. 522. 415. Defendant BANC OF AMERICA designated as Defendant No. 523. MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 37 of 157 PagelD #: 1219 416. Defendant BANC OF AMERICA designated as Defendant No. 524. 417. Defendant BANC OF AMERICA designated as Defendant No. 525. 418. Defendant BANC OF AMERICA designated as Defendant No. 526. 419. Defendant BANC OF AMERICA designated as Defendant No. 527. 420. Defendant BANC OF AMERICA designated as Defendant No. 528. 421. Defendant BANC OF AMERICA designated as Defendant No. 529. 422. Defendant BANC OF AMERICA designated as Defendant No. 530. 423. Defendant BANC OF AMERICA designated as Defendant No. 531. 424. Defendant BANC OF AMERICA designated as Defendant No. 532. 425. Defendant BANC OF AMERICA designated as Defendant No. 533. 426. Defendant BANC OF AMERICA designated as Defendant No. 534. MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be MORTGAGE SECURITIES INC shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 38 of 157 PagelD #: 1220 427. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 535. 428. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 536. 429. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 537. 430. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 538. 431. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 539. 432. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 540. 433. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 541. 434. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 542. 435. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 543. 436. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 544. 437. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2001-23 shall be designated as Defendant No. 545. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 39 of 157 PagelD #: 1221 438. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2001-23 shall be designated as Defendant No. 546. 439. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2002-HYB1 shall be designated as Defendant No. 547. 440. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-10 shall be designated as Defendant No. 548. 441. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-11 shall be designated as Defendant No. 549. 442. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-12 shall be designated as Defendant No. 550. 443. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-13 shall be designated as Defendant No. 551. 444. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-14 shall be designated as Defendant No. 552. 445. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-16 shall be designated as Defendant No. 553. 446. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-18 shall be designated as Defendant No. 554. 447. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-19 shall be designated as Defendant No. 555. 448. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-20 shall be designated as Defendant No. 556. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 40 of 157 PagelD #: 1222 449. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-21 shall be designated as Defendant No. 557. 450. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-22 shall be designated as Defendant No. 558. 451. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-23 shall be designated as Defendant No. 559. 452. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-24 shall be designated as Defendant No. 560. 453. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-5 shall be designated as Defendant No. 561. 454. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-5 shall be designated as Defendant No. 562. 455. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-6 shall be designated as Defendant No. 563. 456. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-7 shall be designated as Defendant No. 564. 457. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-8 shall be designated as Defendant No. 565. 458. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-9 shall be designated as Defendant No. 566. 459. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB7 shall be designated as Defendant No. 567. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 41 of 157 PagelD #: 1223 460. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB8 shall be designated as Defendant No. 568. 461. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB9 shall be designated as Defendant No. 569. 462. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-11 shall be designated as Defendant No. 570. 463. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-12 shall be designated as Defendant No. 571. 464. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-13 shall be designated as Defendant No. 572. 465. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-14 shall be designated as Defendant No. 573. 466. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-15 shall be designated as Defendant No. 574. 467. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-16 shall be designated as Defendant No. 575. 468. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-17 shall be designated as Defendant No. 576. 469. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-18 shall be designated as Defendant No. 577. 470. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-19 shall be designated as Defendant No. 578. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 42 of 157 PagelD #: 1224 471. Defendant CHL MORTGAGE designated as Defendant No. 579. 472. Defendant CHL MORTGAGE designated as Defendant No. 580. 473. Defendant CHL MORTGAGE designated as Defendant No. 581. 474. Defendant CHL MORTGAGE designated as Defendant No. 582. 475. Defendant CHL MORTGAGE designated as Defendant No. 583. 476. Defendant CHL MORTGAGE designated as Defendant No. 584. 477. Defendant CHL MORTGAGE designated as Defendant No. 585. 478. Defendant CHL MORTGAGE designated as Defendant No. 586. 479. Defendant CHL MORTGAGE designated as Defendant No. 587. 480. Defendant CHL MORTGAGE designated as Defendant No. 588. 481. Defendant CHL MORTGAGE designated as Defendant No. 589. PASS-THROUGH TRUST 2005-20 shall be PASS-THROUGH TRUST 2005-21 shall be PASS-THROUGH TRUST 2005-22 shall be PASS-THROUGH TRUST 2005-23 shall be PASS-THROUGH TRUST 2005-24 shall be PASS-THROUGH TRUST 2005-25 shall be PASS-THROUGH TRUST 2005-27 shall be PASS-THROUGH TRUST 2005-27 shall be PASS-THROUGH TRUST 2005-27 shall be PASS-THROUGH TRUST 2005-28 shall be PASS-THROUGH TRUST 2005-28 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 43 of 157 PagelD #: 1225 482. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-28 shall be designated as Defendant No. 590. 483. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 591. 484. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 592. 485. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-29 shall be designated as Defendant No. 593. 486. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-3 shall be designated as Defendant No. 594. 487. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-30 shall be designated as Defendant No. 595. 488. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-31 shall be designated as Defendant No. 596. 489. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-6 shall be designated as Defendant No. 597. 490. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-9 shall be designated as Defendant No. 598. 491. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB1 shall be designated as Defendant No. 599. 492. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB10 shall be designated as Defendant No. 600. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 44 of 157 PagelD #: 1226 493. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB2 shall be designated as Defendant No. 601. 494. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB3 shall be designated as Defendant No. 602. 495. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB4 shall be designated as Defendant No. 603. 496. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB5 shall be designated as Defendant No. 604. 497. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB6 shall be designated as Defendant No. 605. 498. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB7 shall be designated as Defendant No. 606. 499. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-HYB8 shall be designated as Defendant No. 607. 500. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J2 shall be designated as Defendant No. 608. 501. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J3 shall be designated as Defendant No. 609. 502. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2005-J4 shall be designated as Defendant No. 610. 503. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-1 shall be designated as Defendant No. 61 1. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 45 of 157 PagelD #: 1227 504. Defendant CHL MORTGAGE designated as Defendant No. 612. 505. Defendant CHL MORTGAGE designated as Defendant No. 613. 506. Defendant CHL MORTGAGE designated as Defendant No. 614. 507. Defendant CHL MORTGAGE designated as Defendant No. 615. 508. Defendant CHL MORTGAGE designated as Defendant No. 616. 509. Defendant CHL MORTGAGE designated as Defendant No. 617. 510. Defendant CHL MORTGAGE designated as Defendant No. 618. 511. Defendant CHL MORTGAGE designated as Defendant No. 619. 512. Defendant CHL MORTGAGE designated as Defendant No. 620. 513. Defendant CHL MORTGAGE designated as Defendant No. 621. 514. Defendant CHL MORTGAGE designated as Defendant No. 622. PASS-THROUGH TRUST 2006-10 shall be PASS-THROUGH TRUST 2006-11 shall be PASS-THROUGH TRUST 2006-12 shall be PASS-THROUGH TRUST 2006-13 shall be PASS-THROUGH TRUST 2006-14 shall be PASS-THROUGH TRUST 2006-14 shall be PASS-THROUGH TRUST 2006-15 shall be PASS-THROUGH TRUST 2006-15 shall be PASS-THROUGH TRUST 2006-16 shall be PASS-THROUGH TRUST 2006-16 shall be PASS-THROUGH TRUST 2006-16 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 46 of 157 PagelD #: 1228 515. Defendant CHL MORTGAGE designated as Defendant No. 623. 516. Defendant CHL MORTGAGE designated as Defendant No. 624. 517. Defendant CHL MORTGAGE designated as Defendant No. 625. 518. Defendant CHL MORTGAGE designated as Defendant No. 626. 519. Defendant CHL MORTGAGE designated as Defendant No. 627. 520. Defendant CHL MORTGAGE designated as Defendant No. 628. 521. Defendant CHL MORTGAGE designated as Defendant No. 629. 522. Defendant CHL MORTGAGE designated as Defendant No. 630. 523. Defendant CHL MORTGAGE designated as Defendant No. 631. 524. Defendant CHL MORTGAGE designated as Defendant No. 632. 525. Defendant CHL MORTGAGE designated as Defendant No. 633. PASS-THROUGH TRUST 2006-17 shall be PASS-THROUGH TRUST 2006-18 shall be PASS-THROUGH TRUST 2006-18 shall be PASS-THROUGH TRUST 2006-18 shall be PASS-THROUGH TRUST 2006-18 shall be PASS-THROUGH TRUST 2006-19 shall be PASS-THROUGH TRUST 2006-19 shall be PASS-THROUGH TRUST 2006-20 shall be PASS-THROUGH TRUST 2006-20 shall be PASS-THROUGH TRUST 2006-21 shall be PASS-THROUGH TRUST 2006-21 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 47 of 157 PagelD #: 1229 526. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-3 shall be designated as Defendant No. 634. 527. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-6 shall be designated as Defendant No. 635. 528. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-8 shall be designated as Defendant No. 636. 529. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-9 shall be designated as Defendant No. 637. 530. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB1 shall be designated as Defendant No. 638. 531. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB2 shall be designated as Defendant No. 639. 532. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB3 shall be designated as Defendant No. 640. 533. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB4 shall be designated as Defendant No. 641. 534. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-HYB5 shall be designated as Defendant No. 642. 535. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J1 shall be designated as Defendant No. 643. 536. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J2 shall be designated as Defendant No. 644. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 48 of 157 PagelD #: 1230 537. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J3 shall be designated as Defendant No. 645. 538. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-J4 shall be designated as Defendant No. 646. 539. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2006-OA5 shall be designated as Defendant No. 647. 540. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-1 shall be designated as Defendant No. 648. 541. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-10 shall be designated as Defendant No. 649. 542. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-11 shall be designated as Defendant No. 650. 543. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-11 shall be designated as Defendant No. 651. 544. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-12 shall be designated as Defendant No. 652. 545. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-13 shall be designated as Defendant No. 653. 546. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-13 shall be designated as Defendant No. 654. 547. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-14 shall be designated as Defendant No. 655. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 49 of 157 PagelD #: 1231 548. Defendant CHL MORTGAGE designated as Defendant No. 656. 549. Defendant CHL MORTGAGE designated as Defendant No. 657. 550. Defendant CHL MORTGAGE designated as Defendant No. 658. 551. Defendant CHL MORTGAGE designated as Defendant No. 659. 552. Defendant CHL MORTGAGE designated as Defendant No. 660. 553. Defendant CHL MORTGAGE designated as Defendant No. 661. 554. Defendant CHL MORTGAGE designated as Defendant No. 662. 555. Defendant CHL MORTGAGE designated as Defendant No. 663. 556. Defendant CHL MORTGAGE designated as Defendant No. 664. 557. Defendant CHL MORTGAGE designated as Defendant No. 665. 558. Defendant CHL MORTGAGE designated as Defendant No. 666. PASS-THROUGH TRUST 2007-15 shall be PASS-THROUGH TRUST 2007-15 shall be PASS-THROUGH TRUST 2007-16 shall be PASS-THROUGH TRUST 2007-16 shall be PASS-THROUGH TRUST 2007-17 shall be PASS-THROUGH TRUST 2007-17 shall be PASS-THROUGH TRUST 2007-17 shall be PASS-THROUGH TRUST 2007-17 shall be PASS-THROUGH TRUST 2007-18 shall be PASS-THROUGH TRUST 2007-18 shall be PASS-THROUGH TRUST 2007-18 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 50 of 157 PagelD #: 1232 559. Defendant CHL MORTGAGE designated as Defendant No. 667. 560. Defendant CHL MORTGAGE designated as Defendant No. 668. 561. Defendant CHL MORTGAGE designated as Defendant No. 669. 562. Defendant CHL MORTGAGE designated as Defendant No. 670. 563. Defendant CHL MORTGAGE designated as Defendant No. 671. 564. Defendant CHL MORTGAGE designated as Defendant No. 672. 565. Defendant CHL MORTGAGE designated as Defendant No. 673. 566. Defendant CHL MORTGAGE designated as Defendant No. 674. 567. Defendant CHL MORTGAGE designated as Defendant No. 675. 568. Defendant CHL MORTGAGE designated as Defendant No. 676. 569. Defendant CHL MORTGAGE designated as Defendant No. 677. PASS-THROUGH TRUST 2007-19 shall be PASS-THROUGH TRUST 2007-19 shall be PASS-THROUGH TRUST 2007-2 shall be PASS-THROUGH TRUST 2007-2 shall be PASS-THROUGH TRUST 2007-2 shall be PASS-THROUGH TRUST 2007-20 shall be PASS-THROUGH TRUST 2007-20 shall be PASS-THROUGH TRUST 2007-20 shall be PASS-THROUGH TRUST 2007-20 shall be PASS-THROUGH TRUST 2007-21 shall be PASS-THROUGH TRUST 2007-21 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 51 of 157 PagelD #: 1233 570. Defendant CHL MORTGAGE designated as Defendant No. 678. 571. Defendant CHL MORTGAGE designated as Defendant No. 679. 572. Defendant CHL MORTGAGE designated as Defendant No. 680. 573. Defendant CHL MORTGAGE designated as Defendant No. 681. 574. Defendant CHL MORTGAGE designated as Defendant No. 682. 575. Defendant CHL MORTGAGE designated as Defendant No. 683. 576. Defendant CHL MORTGAGE designated as Defendant No. 684. 577. Defendant CHL MORTGAGE designated as Defendant No. 685. 578. Defendant CHL MORTGAGE designated as Defendant No. 686. 579. Defendant CHL MORTGAGE designated as Defendant No. 687. 580. Defendant CHL MORTGAGE designated as Defendant No. 688. PASS-THROUGH TRUST 2007-3 shall be PASS-THROUGH TRUST 2007-3 shall be PASS-THROUGH TRUST 2007-4 shall be PASS-THROUGH TRUST 2007-4 shall be PASS-THROUGH TRUST 2007-4 shall be PASS-THROUGH TRUST 2007-5 shall be PASS-THROUGH TRUST 2007-5 shall be PASS-THROUGH TRUST 2007-5 shall be PASS-THROUGH TRUST 2007-6 shall be PASS-THROUGH TRUST 2007-7 shall be PASS-THROUGH TRUST 2007-8 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 52 of 157 PagelD #: 1234 581. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-8 shall be designated as Defendant No. 689. 582. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 690. 583. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 691. 584. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 692. 585. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 693. 586. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 694. 587. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-9 shall be designated as Defendant No. 695. 588. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY1 shall be designated as Defendant No. 696. 589. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY3 shall be designated as Defendant No. 697. 590. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY3 shall be designated as Defendant No. 698. 591. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY4 shall be designated as Defendant No. 699. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 53 of 157 PagelD #: 1235 592. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY5 shall be designated as Defendant No. 700. 593. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY6 shall be designated as Defendant No. 701. 594. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 702. 595. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 703. 596. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HY7 shall be designated as Defendant No. 704. 597. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB1 shall be designated as Defendant No. 705. 598. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB2 shall be designated as Defendant No. 706. 599. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-HYB2 shall be designated as Defendant No. 707. 600. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J1 shall be designated as Defendant No. 708. 601. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J1 shall be designated as Defendant No. 709. 602. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2007-J2 shall be designated as Defendant No. 710. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 54 of 157 PagelD #: 1236 603. Defendant CHL MORTGAGE designated as Defendant No. 711. 604. Defendant CHL MORTGAGE designated as Defendant No. 712. 605. Defendant CHL MORTGAGE designated as Defendant No. 713. 606. Defendant CHL MORTGAGE designated as Defendant No. 714. 607. Defendant CHL MORTGAGE designated as Defendant No. 715. 608. Defendant CHL MORTGAGE designated as Defendant No. 716. 609. Defendant CHL MORTGAGE designated as Defendant No. 717. 610. Defendant CHL MORTGAGE designated as Defendant No. 718. 611. Defendant CHL MORTGAGE designated as Defendant No. 719. 612. Defendant CHL MORTGAGE designated as Defendant No. 720. 613. Defendant CHL MORTGAGE designated as Defendant No. 721. PASS-THROUGH TRUST 2007-J2 shall be PASS-THROUGH TRUST 2007-J2 shall be PASS-THROUGH TRUST 2007-J2 shall be PASS-THROUGH TRUST 2007-J2 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be PASS-THROUGH TRUST 2007-J3 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 55 of 157 PagelD #: 1237 614. Defendant CHL MORTGAGE PASS-THROUGH TRUST 2008-1 shall be designated as Defendant No. 722. 615. Defendant CHL MORTGAGE PASS-THROUGH TRUST RESECURITIZATION 2008-2R shall be designated as Defendant No. 723. 616. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-HYB5 shall be designated as Defendant No. 724. 617. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-J7 shall be designated as Defendant No. 725. 618. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-J8 shall be designated as Defendant No. 726. 619. Defendant CWMBS CHL MORTGAGE PASS-THROUGH TRUST 2004-J9 shall be designated as Defendant No. 727. 620. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2004- 25 shall be designated as Defendant No. 728. 621 . Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2004- 29 shall be designated as Defendant No. 729. 622. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 2 shall be designated as Defendant No. 730. 623. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 4 shall be designated as Defendant No. 731. 624. Defendant CWMBS INC - CHL MORTGAGE PASS-THROUGH TRUST 2005- 5 shall be designated as Defendant No. 732. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 56 of 157 PagelD #: 1238 625. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2002- 21 shall be designated as Defendant No. 733. 626. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2002- 21 shall be designated as Defendant No. 734. 627. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 735. 628. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 736. 629. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 737. 630. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 738. 631. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003 4 shall be designated as Defendant No. 739. 632. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 26 shall be designated as Defendant No. 740. 633. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 26 shall be designated as Defendant No. 741. 634. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003-3 shall be designated as Defendant No. 742. 635. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 42 shall be designated as Defendant No. 743. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 57 of 157 PagelD #: 1239 636. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 42 shall be designated as Defendant No. 744. 637. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2003- 48 shall be designated as Defendant No. 745. 638. Defendant CWMBS INC CHL MORTGAGE PASS-THROUGH TRUST 2004- J3 shall be designated as Defendant No. 746. 639. Defendant CWMBS, INC. - CHL MORTGAGE PASS-THROUGH TRUST 2005-1 shall be designated as Defendant No. 747. 640. Defendant CWMBS, INC. - CHL MORTGAGE PASS-THROUGH TRUST 2005-7 shall be designated as Defendant No. 748. 641 . Defendant CWMBS, INC., CHL MORTGAGE PASS-THROUGH TRUST 2005- 26 shall be designated as Defendant No. 749. 642. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-3 shall be designated as Defendant No. 750. 643. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2003-5 shall be designated as Defendant No. 751. 644. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-1 shall be designated as Defendant No. 752. 645. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-2 shall be designated as Defendant No. 753. 646. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-3 shall be designated as Defendant No. 754. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 58 of 157 PagelD #: 1240 647. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-4 shall be designated as Defendant No. 755. 648. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5 shall be designated as Defendant No. 756. 649. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-8 shall be designated as Defendant No. 757. 650. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-9 shall be designated as Defendant No. 758. 651. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-10 shall be designated as Defendant No. 759. 652. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-11 shall be designated as Defendant No. 760. 653. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-12 shall be designated as Defendant No. 761. 654. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-4 shall be designated as Defendant No. 762. 655. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-5 shall be designated as Defendant No. 763. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 59 of 157 PagelD #: 1241 656. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-6 shall be designated as Defendant No. 764. 657. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-7 shall be designated as Defendant No. 765. 658. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-8 shall be designated as Defendant No. 766. 659. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-9 shall be designated as Defendant No. 767. 660. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-1 shall be designated as Defendant No. 768. 661. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-10 shall be designated as Defendant No. 769. 662. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-11 shall be designated as Defendant No. 770. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 60 of 157 PagelD #: 1242 663. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-2 shall be designated as Defendant No. 771. 664. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-3 shall be designated as Defendant No. 772. 665. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-4 shall be designated as Defendant No. 773. 666. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-5 shall be designated as Defendant No. 774. 667. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-6 shall be designated as Defendant No. 775. 668. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-7 shall be designated as Defendant No. 776. 669. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-8 shall be designated as Defendant No. 777. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 61 of 157 PagelD #: 1243 670. Defendant BANC OF AMERICA ALTERNATIVE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2005-9 shall be designated as Defendant No. 778. 671. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2003 1 1 shall be designated as Defendant No. 779. 672. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVE LOAN TRUST 2004 2 shall be designated as Defendant No. 780. 673. Defendant BANC OF AMERICA MORT SEC INC ALTERNATIVER LOAN TRUST 2003-10 shall be designated as Defendant No. 781. 674. Defendant BANC OF AMERICA MORTGAGE SECURITIES INC shall be designated as Defendant No. 782. 675. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-3, ASSET- BACKED CERTS., SERIES 2004-3 shall be designated as Defendant No. 783. 676. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-4, ASSET- BACKED CERTS., SERIES 2004-4 shall be designated as Defendant No. 784. 677. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-5, ASSET- BACKED CERTS., SERIES 2004-5 shall be designated as Defendant No. 785. 678. Defendant LONG BEACH MORTGAGE LOAN TRUST 2004-6, ASSET- BACKED CERTS., SERIES 2004-6 shall be designated as Defendant No. 786. 679. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-1, ASSET- BACKED CERTS., SERIES 2005-1 shall be designated as Defendant No. 787. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 62 of 157 PagelD #: 1244 680. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-2 ASSET- BACKED CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 788. 681. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-3 ASSET- BACKED CERTIFICATES, SERIES 2005-3 shall be designated as Defendant No. 789. 682. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL1 ASSET- BACKED CERTIFICATES, SERIES 2005-WL1 shall be designated as Defendant No. 790. 683. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL2 ASSET- BACKED CERTIFICATES shall be designated as Defendant No. 791. 684. Defendant LONG BEACH MORTGAGE LOAN TRUST 2005-WL3 shall be designated as Defendant No. 792. 685. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-1 shall be designated as Defendant No. 793. 686. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-1 shall be designated as Defendant No. 794. 687. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-10 shall be designated as Defendant No. 795. 688. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-10 shall be designated as Defendant No. 796. 689. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 797. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 63 of 157 PagelD #: 1245 690. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 798. 691. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-11 shall be designated as Defendant No. 799. 692. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 800. 693. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 801. 694. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-2 shall be designated as Defendant No. 802. 695. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 803. 696. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 804. 697. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-3 shall be designated as Defendant No. 805. 698. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 806. 699. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 807. 700. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 808. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 64 of 157 PagelD #: 1246 701. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-5 shall be designated as Defendant No. 809. 702. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-5 shall be designated as Defendant No. 810. 703. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-6 shall be designated as Defendant No. 811. 704. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-6 shall be designated as Defendant No. 812. 705. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 813. 706. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 814. 707. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-7 shall be designated as Defendant No. 815. 708. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-8 shall be designated as Defendant No. 816. 709. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-8 shall be designated as Defendant No. 817. 710. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-9 shall be designated as Defendant No. 818. 711. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-9 shall be designated as Defendant No. 819. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 65 of 157 PagelD #: 1247 712. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-A shall be designated as Defendant No. 820. 713. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-A shall be designated as Defendant No. 821. 714. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL1 shall be designated as Defendant No. 822. 715. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL1 shall be designated as Defendant No. 823. 716. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL2 shall be designated as Defendant No. 824. 717. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL2 shall be designated as Defendant No. 825. 718. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL3 shall be designated as Defendant No. 826. 719. Defendant LONG BEACH MORTGAGE LOAN TRUST 2006-WL3 shall be designated as Defendant No. 827. 720. Defendant LONG BEACH SECURITIES CORP shall be designated as Defendant No. 828. 721. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE1 shall be designated as Defendant No. 829. 722. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE2 shall be designated as Defendant No. 830. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 66 of 157 PagelD #: 1248 723. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE3 shall be designated as Defendant No. 831. 724. Defendant WAMU ASSET-BACKED CERTIFICATES, WAMU SERIES 2007- HE4 shall be designated as Defendant No. 832. 725. Defendant WAMU MOR PASS THRU CERT SER 2001-AR1 shall be designated as Defendant No. 833. 726. Defendant WAMU MORTAGE PASS THRU CERT SER 2003-S8 shall be designated as Defendant No. 834. 727. Defendant WAMU MORTAGE PASS THRU CERT SERIES 2003-AR3 shall be designated as Defendant No. 835. 728. Defendant WAMU MORTGAGE PASS THR CERTS SER 2003-AR12 shall be designated as Defendant No. 836. 729. Defendant WAMU MORTGAGE PASS THROUGH CER SER 2003-AR8 shall be designated as Defendant No. 837. 730. Defendant WAMU MORTGAGE PASS THROUGH CERT 2002- AR10 shall be designated as Defendant No. 838. 731. Defendant WAMU MORTGAGE PASS THROUGH CERT 2002- AR10 shall be designated as Defendant No. 839. 732. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2002-AR19 shall be designated as Defendant No. 840. 733. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2002-AR19 shall be designated as Defendant No. 841. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 67 of 157 PagelD #: 1249 734. Defendant WAMU MORTGAGE PASS THROUGH CERT SER 2003-S1 shall be designated as Defendant No. 842. 735 . Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 200 1 -5 shall be designated as Defendant No. 843. 736. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2001-S8 shall be designated as Defendant No. 844. 737. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2002-S8 shall be designated as Defendant No. 845. 738. Defendant WAMU MORTGAGE PASS THROUGH CERT SERIES 2002-S8 shall be designated as Defendant No. 846. 739. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S1 shall be designated as Defendant No. 847. 740. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S1 shall be designated as Defendant No. 848. 741. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S7 shall be designated as Defendant No. 849. 742. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES 2002-S7 shall be designated as Defendant No. 850. 743. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR2 shall be designated as Defendant No. 851. 744. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR3 shall be designated as Defendant No. 852. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 68 of 157 PagelD #: 1250 745. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001-AR4 shall be designated as Defendant No. 853. 746. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2001 - SI 1 shall be designated as Defendant No. 854. 747. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR12 shall be designated as Defendant No. 855. 748. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR12 shall be designated as Defendant No. 856. 749. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR14 shall be designated as Defendant No. 857. 750. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002 AR14 shall be designated as Defendant No. 858. 751. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002- AR1 1 shall be designated as Defendant No. 859. 752. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR13 shall be designated as Defendant No. 860. 753. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR13 shall be designated as Defendant No. 861. 754. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR15 shall be designated as Defendant No. 862. 755. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR15 shall be designated as Defendant No. 863. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 69 of 157 PagelD #: 1251 756. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR16 shall be designated as Defendant No. 864. 757. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR17 shall be designated as Defendant No. 865. 758. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR17 shall be designated as Defendant No. 866. 759. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR3 shall be designated as Defendant No. 867. 760. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-AR3 shall be designated as Defendant No. 868. 761. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S2 shall be designated as Defendant No. 869. 762. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S2 shall be designated as Defendant No. 870. 763. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S3 shall be designated as Defendant No. 871. 764. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S3 shall be designated as Defendant No. 872. 765. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S4 shall be designated as Defendant No. 873. 766. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002-S6 shall be designated as Defendant No. 874. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 70 of 157 PagelD #: 1252 767. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2002- S6 shall be designated as Defendant No. 875. 768. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003 S3 shall be designated as Defendant No. 876. 769. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003 S4 shall be designated as Defendant No. 877. 770. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003- AR1 shall be designated as Defendant No. 878. 771. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR4 shall be designated as Defendant No. 879. 772. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR5 shall be designated as Defendant No. 880. 773. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-AR6 shall be designated as Defendant No. 881. 774. Defendant WAMU MORTGAGE PASS THROUGH CERTIFICATES SERIES 2003-S2 shall be designated as Defendant No. 882. 775. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-AR10 shall be designated as Defendant No. 883. 776. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S10 shall be designated as Defendant No. 884. 777. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S11 shall be designated as Defendant No. 885. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 71 of 157 PagelD #: 1253 778. Defendant WAMU MORTGAGE PASS THROUGH CERTS SER 2003-S9 shall be designated as Defendant No. 886. 779. Defendant WAMU MORTGAGE PASS THROUGH CERTS SERIES 2003-S5 shall be designated as Defendant No. 887. 780. Defendant WAMU MORTGAGE PASS THROUGH CERTS SERIES 2004-S1 shall be designated as Defendant No. 888. 781. Defendant WAMU MORTGAGE PASS THRU CERTIFICATE SERIES 2001- AR6 shall be designated as Defendant No. 889. 782. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS8 shall be designated as Defendant No. 890. 783. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS8 shall be designated as Defendant No. 891. 784. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS9 shall be designated as Defendant No. 892. 785. Defendant WAMU MORTGAGE PASS THRU CERTIFICATES SERIES 2002- MS9 shall be designated as Defendant No. 893. 786. Defendant WAMU MORTGAGE PASS THRU CERTS SERIES 2002-ARS shall be designated as Defendant No. 894. 787. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2002-AR4 shall be designated as Defendant No. 895. 788. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATE SERIES 2002-AR4 shall be designated as Defendant No. 896. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 72 of 157 PagelD #: 1254 789. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SER 2003-S12 shall be designated as Defendant No. 897. 790. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2001-S10 shall be designated as Defendant No. 898. 791. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2003- S7 shall be designated as Defendant No. 899. 792. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004 AR-3 shall be designated as Defendant No. 900. 793. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004- AR1 shall be designated as Defendant No. 901. 794. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-AR2 shall be designated as Defendant No. 902. 795. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-AR4 shall be designated as Defendant No. 903. 796. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-AR6 shall be designated as Defendant No. 904. 797. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-CB1 shall be designated as Defendant No. 905. 798. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-RS2 shall be designated as Defendant No. 906. 799. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-S2 shall be designated as Defendant No. 907. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 73 of 157 PagelD #: 1255 800. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR10 shall be designated as Defendant No. 908. 801. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR1 1 shall be designated as Defendant No. 909. 802. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR1 1 shall be designated as Defendant No. 910. 803. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR12 shall be designated as Defendant No. 91 1 . 804. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR13 shall be designated as Defendant No. 912. 805. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR14 shall be designated as Defendant No. 913. 806. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR5 shall be designated as Defendant No. 914. 807. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR7 shall be designated as Defendant No. 915. 808. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR8 shall be designated as Defendant No. 916. 809. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR9 shall be designated as Defendant No. 917. 810. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB2 shall be designated as Defendant No. 918. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 74 of 157 PagelD #: 1256 811. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB3 shall be designated as Defendant No. 919. 812. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-CB4 shall be designated as Defendant No. 920. 813. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- S3 shall be designated as Defendant No. 921. 814. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005- AR1 shall be designated as Defendant No. 922. 815. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR1 shall be designated as Defendant No. 923. 816. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR10 shall be designated as Defendant No. 924. 817. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR1 1 shall be designated as Defendant No. 925. 818. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR1 1 shall be designated as Defendant No. 926. 819. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR12 shall be designated as Defendant No. 927. 820. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR13 shall be designated as Defendant No. 928. 821. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR13 shall be designated as Defendant No. 929. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 75 of 157 PagelD #: 1257 822. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR14 shall be designated as Defendant No. 930. 823. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR15 shall be designated as Defendant No. 931. 824. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR16 shall be designated as Defendant No. 932. 825. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR17 shall be designated as Defendant No. 933. 826. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR18 shall be designated as Defendant No. 934. 827. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR19 shall be designated as Defendant No. 935. 828. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR2 shall be designated as Defendant No. 936. 829. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR2 shall be designated as Defendant No. 937. 830. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR3 shall be designated as Defendant No. 938. 831. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR4 shall be designated as Defendant No. 939. 832. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR5 shall be designated as Defendant No. 940. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 76 of 157 PagelD #: 1258 833. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR6 shall be designated as Defendant No. 941. 834. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR6 shall be designated as Defendant No. 942. 835. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR7 shall be designated as Defendant No. 943. 836. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR8 shall be designated as Defendant No. 944. 837. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR8 shall be designated as Defendant No. 945. 838. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-AR9 shall be designated as Defendant No. 946. 839. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005- AR9 shall be designated as Defendant No. 947. 840. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006- AR1 shall be designated as Defendant No. 948. 841. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR10 shall be designated as Defendant No. 949. 842. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR1 1 shall be designated as Defendant No. 950. 843. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR12 shall be designated as Defendant No. 95 1 . Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 77 of 157 PagelD #: 1259 844. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR13 shall be designated as Defendant No. 952. 845. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR14 shall be designated as Defendant No. 953. 846. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR15 shall be designated as Defendant No. 954. 847. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR16 shall be designated as Defendant No. 955. 848. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR17 shall be designated as Defendant No. 956. 849. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR18 shall be designated as Defendant No. 957. 850. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR19 shall be designated as Defendant No. 958. 851. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR2 shall be designated as Defendant No. 959. 852. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR3 shall be designated as Defendant No. 960. 853. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR4 shall be designated as Defendant No. 961. 854. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR5 shall be designated as Defendant No. 962. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 78 of 157 PagelD #: 1260 855. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR6 shall be designated as Defendant No. 963. 856. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR7 shall be designated as Defendant No. 964. 857. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR8 shall be designated as Defendant No. 965. 858. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006- AR9 shall be designated as Defendant No. 966. 859. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007- HY1 shall be designated as Defendant No. 967. 860. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY2 shall be designated as Defendant No. 968. 861. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY3 shall be designated as Defendant No. 969. 862. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY4 shall be designated as Defendant No. 970. 863. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY5 shall be designated as Defendant No. 971. 864. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY6 shall be designated as Defendant No. 972. 865. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-HY7 shall be designated as Defendant No. 973. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 79 of 157 PagelD #: 1261 866. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA1 shall be designated as Defendant No. 974. 867. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA2 shall be designated as Defendant No. 975. 868. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA3 shall be designated as Defendant No. 976. 869. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA4 shall be designated as Defendant No. 977. 870. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA5 shall be designated as Defendant No. 978. 871. Defendant WAMU MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-OA6 shall be designated as Defendant No. 979. 872. Defendant WAMU MORTGAGE PASS-THRU CERT SERIES 2003-AR2 shall be designated as Defendant No. 980. 873. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 02 AR7 shall be designated as Defendant No. 981. 874. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 02 AR7 shall be designated as Defendant No. 982. 875. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 03 S6 shall be designated as Defendant No. 983. 876. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002 S5 shall be designated as Defendant No. 984. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 80 of 157 PagelD #: 1262 877. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002 S5 shall be designated as Defendant No. 985. 878. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002-AR9 shall be designated as Defendant No. 986. 879. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CE SE 2002-AR9 shall be designated as Defendant No. 987. 880. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CER SE 02 AR18 shall be designated as Defendant No. 988. 881. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PA TH CER SE 02 AR18 shall be designated as Defendant No. 989. 882. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 AR9 shall be designated as Defendant No. 990. 883. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 AR9 shall be designated as Defendant No. 991. 884. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MO PS TH CE SE 03 S13 shall be designated as Defendant No. 992. 885. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU MOR PAS TH CE SE 03 AR7 shall be designated as Defendant No. 993. 886. Defendant WASHINGTON MUTUAL MORT SEC CORP WAMU SERIES 2003-AR1 1 shall be designated as Defendant No. 994. 887. Defendant WASHINGTON MUTUAL MORT SEC WAMU MOR PA TH CE SE 2002 AR2 shall be designated as Defendant No. 995. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 81 of 157 PagelD #: 1263 888. Defendant AMERIQUEST MORTGAGE SECURITIES INC shall be designated as Defendant No. 996. 889. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R4 shall be designated as Defendant No. 997. 890. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R6 shall be designated as Defendant No. 998. 891. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R7 shall be designated as Defendant No. 999. 892. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R8 shall be designated as Defendant No. 1000. 893. Defendant AMERIQUEST MORTGAGE SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R9 shall be designated as Defendant No. 1001. 894. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-IA1 shall be designated as Defendant No. 1002. 895. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R10 shall be designated as Defendant No. 1003. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 82 of 157 PagelD #: 1264 896. Defendant AMERIQUEST MORTGAGE SECURITIES INC. ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-R11 shall be designated as Defendant No. 1004. 897. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-1 shall be designated as Defendant No. 1005. 898. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-6 shall be designated as Defendant No. 1006. 899. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR2 shall be designated as Defendant No. 1007. 900. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2003-AR3 shall be designated as Defendant No. 1008. 901 . Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R10 shall be designated as Defendant No. 1009. 902. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R5 shall be designated as Defendant No. 1010. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 83 of 157 PagelD #: 1265 903. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R6 shall be designated as Defendant No. 1011. 904. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R7 shall be designated as Defendant No. 1012. 905. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R8 shall be designated as Defendant No. 1013. 906. Defendant AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R9 shall be designated as Defendant No. 1014. 907. Defendant AMERIQUEST MORTGAGE SECURITIES TRUST 2006-R1, ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-R1 shall be designated as Defendant No. 1015. 908. Defendant ARGENT SECURITIES INC shall be designated as Defendant No. 1016. 909. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004-W7 shall be designated as Defendant No. 1017. 910. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-PW1 shall be designated as Defendant No. 1018. 911. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-W10 shall be designated as Defendant No. 1019. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 84 of 157 PagelD #: 1266 912. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-W1 1 shall be designated as Defendant No. 1020. 913. Defendant ARGENT SECURITIES INC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-W9 shall be designated as Defendant No. 1021. 914. Defendant ARGENT SECURITIES INC. , ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-W1 shall be designated as Defendant No. 1022. 915. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W2 shall be designated as Defendant No. 1023. 916. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W3 shall be designated as Defendant No. 1024. 917. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W4 shall be designated as Defendant No. 1025. 918. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-W5 shall be designated as Defendant No. 1026. 919. Defendant ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-W2 shall be designated as Defendant No. 1027. 920. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2003-W7 shall be designated as Defendant No. 1028. 921. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2003- W7 shall be designated as Defendant No. 1029. 922. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004- R2 shall be designated as Defendant No. 1030. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 85 of 157 PagelD #: 1267 923. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2004- W1 shall be designated as Defendant No. 1031. 924. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES SERIES 2005- R2 shall be designated as Defendant No. 1032. 925. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-R12 shall be designated as Defendant No. 1033. 926. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2004- R5 shall be designated as Defendant No. 1034. 927. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005- R4 shall be designated as Defendant No. 1035. 928. Defendant ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-R4 shall be designated as Defendant No. 1036. 929. Defendant CARRINGTON HOME EQUITY LOAN TRUST, SERIES 2005-NC4 ASSET-BACKED PASS-THROUGH CERTIFICATES shall be designated as Defendant No. 1037. 930. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE1, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WFHE1 shall be designated as Defendant No. 1038. 931. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1039. 932. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1040. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 86 of 157 PagelD #: 1268 933. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1041. 934. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1042. 935. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WMC1 shall be designated as Defendant No. 1043. 936. Defendant GE-WMC ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1044. 937. Defendant HOMESTAR MORTGAGE ACCEPTANCE CORP ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2004-4 shall be designated as Defendant No. 1045. 938. Defendant MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-QS9 shall be designated as Defendant No. 1046. 939. Defendant MORTGAGE ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-QS9 shall be designated as Defendant No. 1047. 940. Defendant OPTEUM MORTGAGE ACCEPTANCE CORP shall be designated as Defendant No. 1048. 941. Defendant OPTEUM MORTGAGE ACCEPTANCE CORP. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-4 shall be designated as Defendant No. 1049. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 87 of 157 PagelD #: 1269 942. Defendant PARK PLACE SECURITIES INC ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCW1 shall be designated as Defendant No. 1050. 943. Defendant PARK PLACE SECURITIES, INC. shall be designated as Defendant No. 1051. 944. Defendant PARK PLACE SECURITIES, INC. ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-MCW1 shall be designated as Defendant No. 1052. 945. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-MHQ1 shall be designated as Defendant No. 1053. 946. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCH1 shall be designated as Defendant No. 1054. 947. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WCW2 shall be designated as Defendant No. 1055. 948. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WHQ1 shall be designated as Defendant No. 1056. 949. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WHQ2 shall be designated as Defendant No. 1057. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 88 of 157 PagelD #: 1270 950. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2004-WWF1 shall be designated as Defendant No. 1058. 951. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW2 shall be designated as Defendant No. 1059. 952. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW2 shall be designated as Defendant No. 1060. 953. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WCW3 shall be designated as Defendant No. 1061. 954. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ1 shall be designated as Defendant No. 1062. 955. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ1 shall be designated as Defendant No. 1063. 956. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WHQ4 shall be designated as Defendant No. 1064. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 89 of 157 PagelD #: 1271 957. Defendant PARK PLACE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES, SERIES 2005-WLL1 shall be designated as Defendant No. 1065. 958. Defendant AMERICAN HOME MORT SECURITIES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1066. 959. Defendant AMERICAN HOME MORT SECURITIES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1067. 960. Defendant AMERICAN HOME MORT SECUTIES HOME MORTGAGE INVEST TR 2004-1 shall be designated as Defendant No. 1068. 961 . Defendant AMERICAN HOME MORTGAGE ASSETS LLC shall be designated as Defendant No. 1069. 962. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2005-1 shall be designated as Defendant No. 1070. 963. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2005-2 shall be designated as Defendant No. 1071. 964. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-1 shall be designated as Defendant No. 1072. 965. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-2 shall be designated as Defendant No. 1073. 966. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-2 shall be designated as Defendant No. 1074. 967. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-3 shall be designated as Defendant No. 1075. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 90 of 157 PagelD #: 1272 968. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-4 shall be designated as Defendant No. 1076. 969. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-4 shall be designated as Defendant No. 1077. 970. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-5 shall be designated as Defendant No. 1078. 971. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2006-6 shall be designated as Defendant No. 1079. 972. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-1 shall be designated as Defendant No. 1080. 973. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-2 shall be designated as Defendant No. 1081. 974. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-3 shall be designated as Defendant No. 1082. 975. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-4 shall be designated as Defendant No. 1083. 976. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-4 shall be designated as Defendant No. 1084. 977. Defendant AMERICAN HOME MORTGAGE ASSETS TRUST 2007-5 shall be designated as Defendant No. 1085. 978. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1086. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 91 of 157 PagelD #: 1273 979. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1087. 980. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1088. 981. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1089. 982. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1090. 983. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1091. 984. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1092. 985. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1093. 986. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1094. 987. Defendant AMERICAN HOME MORTGAGE INVESTMENT CORP shall be designated as Defendant No. 1095. 988. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1096. 989. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2004-2 shall be designated as Defendant No. 1097. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 92 of 157 PagelD #: 1274 990. Defendant AMERICAN HOME shall be designated as Defendant No. 991. Defendant AMERICAN HOME shall be designated as Defendant No. 992. Defendant AMERICAN HOME shall be designated as Defendant No. 993. Defendant AMERICAN HOME shall be designated as Defendant No. 994. Defendant AMERICAN HOME shall be designated as Defendant No. 995. Defendant AMERICAN HOME shall be designated as Defendant No. 996. Defendant AMERICAN HOME shall be designated as Defendant No. 997. Defendant AMERICAN HOME shall be designated as Defendant No. 998. Defendant AMERICAN HOME shall be designated as Defendant No. 999. Defendant AMERICAN HOME shall be designated as Defendant No. 1000. Defendant AMERICAN HOME shall be designated as Defendant No. MORTGAGE INVESTMENT TRUST 2004-2 1098. MORTGAGE INVESTMENT TRUST 2004-2 1099. MORTGAGE INVESTMENT TRUST 2004-2 1100. MORTGAGE INVESTMENT TRUST 2004-3 1101. MORTGAGE INVESTMENT TRUST 2004-3 1102. MORTGAGE INVESTMENT TRUST 2004-3 1103. MORTGAGE INVESTMENT TRUST 2004-4 1104. MORTGAGE INVESTMENT TRUST 2004-4 1105. MORTGAGE INVESTMENT TRUST 2004-4 1106. MORTGAGE INVESTMENT TRUST 2004-4 1107. MORTGAGE INVESTMENT TRUST 2004-4 1108. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 93 of 157 PagelD #: 1275 1001. Defendant AMERICAN HOME shall be designated as Defendant No. 1002. Defendant AMERICAN HOME shall be designated as Defendant No. 1003. Defendant AMERICAN HOME shall be designated as Defendant No. 1004. Defendant AMERICAN HOME shall be designated as Defendant No. 1005. Defendant AMERICAN HOME shall be designated as Defendant No. 1006. Defendant AMERICAN HOME shall be designated as Defendant No. 1007. Defendant AMERICAN HOME shall be designated as Defendant No. 1008. Defendant AMERICAN HOME shall be designated as Defendant No. 1009. Defendant AMERICAN HOME shall be designated as Defendant No. 1010. Defendant AMERICAN HOME shall be designated as Defendant No. 1011. Defendant AMERICAN HOME shall be designated as Defendant No. MORTGAGE INVESTMENT TRUST 2005-1 1109. MORTGAGE INVESTMENT TRUST 2005-1 1110. MORTGAGE INVESTMENT TRUST 2005-1 1111. MORTGAGE INVESTMENT TRUST 2005-1 1112. MORTGAGE INVESTMENT TRUST 2005-2 1113. MORTGAGE INVESTMENT TRUST 2005-2 1114. MORTGAGE INVESTMENT TRUST 2005-2 1115. MORTGAGE INVESTMENT TRUST 2005-3 1116. MORTGAGE INVESTMENT TRUST 2005-4 1117. MORTGAGE INVESTMENT TRUST 2005-4 1118. MORTGAGE INVESTMENT TRUST 2005-4 1119. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 94 of 157 PagelD #: 1276 1012. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2005-4 shall be designated as Defendant No. 1 120. 1013. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-1 shall be designated as Defendant No. 1121. 1014. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-2 shall be designated as Defendant No. 1 122. 1015. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-2 shall be designated as Defendant No. 1 123. 1016. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2006-3 shall be designated as Defendant No. 1 124. 1017. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-1 shall be designated as Defendant No. 1 125. 1018. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 126. 1019. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 127. 1020. Defendant AMERICAN HOME MORTGAGE INVESTMENT TRUST 2007-2 shall be designated as Defendant No. 1 128. 1021. Defendant CITICORP MORTGAGE SEC INC REMIC CER SERIES 2003-9 shall be designated as Defendant No. 1 129. 1022. Defendant CITICORP MORTGAGE SEC INC REMIC PASS THR CER SER 2003-3 shall be designated as Defendant No. 1 130. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 95 of 157 PagelD #: 1277 1023. Defendant CITICORP MORTGAGE SEC INC REMIC PASS THR CERTS SERIES 2003 5 shall be designated as Defendant No. 1 131. 1024. Defendant CITICORP MORTGAGE SEC INC REMIC PASS-THR CERT SER 2003-4 shall be designated as Defendant No. 1 132. 1025. Defendant CITICORP MORTGAGE SECURITIES INC shall be designated as Defendant No. 1133. 1026. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-1 shall be designated as Defendant No. 1 134. 1027. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-2 shall be designated as Defendant No. 1 135. 1028. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-3 shall be designated as Defendant No. 1 136. 1029. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-4 shall be designated as Defendant No. 1 137. 1030. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-5 shall be designated as Defendant No. 1138. 1031. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-6 shall be designated as Defendant No. 1 139. 1032. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2006-7 shall be designated as Defendant No. 1 140. 1033. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2007-1 shall be designated as Defendant No. 1141. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 96 of 157 PagelD #: 1278 1034. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 142. 1035. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 143. 1036. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 144. 1037. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 145. 1038. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 146. 1039. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 147. 1040. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 148. 1041. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 149. 1042. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 150. 1043. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1151. 1044. Defendant CITICORP MORTGAGE shall be designated as Defendant No. 1 152. SECURITIES TRUST, SERIES 2007-2 SECURITIES TRUST, SERIES 2007-2 SECURITIES TRUST, SERIES 2007-3 SECURITIES TRUST, SERIES 2007-4 SECURITIES TRUST, SERIES 2007-5 SECURITIES TRUST, SERIES 2007-6 SECURITIES TRUST, SERIES 2007-7 SECURITIES TRUST, SERIES 2007-7 SECURITIES TRUST, SERIES 2007-7 SECURITIES TRUST, SERIES 2007-8 SECURITIES TRUST, SERIES 2007-9 Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 97 of 157 PagelD #: 1279 1045. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2008-1 shall be designated as Defendant No. 1 153. 1046. Defendant CITICORP MORTGAGE SECURITIES TRUST, SERIES 2008-2 shall be designated as Defendant No. 1 154. 1047. Defendant CITICORP RESIDENTIAL MORTGAGE SECURITIES, INC. shall be designated as Defendant No. 1155. 1048. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-1 shall be designated as Defendant No. 1 156. 1049. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-1 shall be designated as Defendant No. 1 157. 1050. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-2 shall be designated as Defendant No. 1158. 1051. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-2 shall be designated as Defendant No. 1 159. 1052. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-3 shall be designated as Defendant No. 1 160. 1053. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2006-3 shall be designated as Defendant No. 1161. 1054. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-1 shall be designated as Defendant No. 1 162. 1055. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-1 shall be designated as Defendant No. 1 163. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 98 of 157 PagelD #: 1280 1056. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-2 shall be designated as Defendant No. 1 164. 1057. Defendant CITICORP RESIDENTIAL MORTGAGE TRUST SERIES 2007-2 shall be designated as Defendant No. 1 165. 1058. Defendant CITIGROUP MORT LN TR ASST BACK PS THR CERTS SER 2003-HE3 shall be designated as Defendant No. 1 166. 1059. Defendant CITIGROUP MORT LOAN TRUST INC ASSET BK PAS THR CE SE 03 HE2 shall be designated as Defendant No. 1 167. 1060. Defendant CITIGROUP MORT LOAN TRUST INC MORT PAS THR CERT SE 03 1 shall be designated as Defendant No. 1 168. 1061. Defendant CITIGROUP MORTGAG LOAN TRUST SERIES 2003-UP3 shall be designated as Defendant No. 1 169. 1062. Defendant CITIGROUP MORTGAGE LOAN TRUST 2005-11 shall be designated as Defendant No. 1 170. 1063. Defendant CITIGROUP MORTGAGE LOAN TRUST 2005-6 shall be designated as Defendant No. 1171. 1064. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 172. 1065. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 173. 1066. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-4 shall be designated as Defendant No. 1 174. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 99 of 157 PagelD #: 1281 1067. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 175. 1068. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 176. 1069. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 177. 1070. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 178. 1071. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 179. 1072. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 180. 1073. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1181. 1074. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 182. 1075. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 183. 1076. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 184. 1077. Defendant CITIGROUP MORTGAGE designated as Defendant No. 1 185. LOAN TRUST 2006-AMC1 shall be LOAN TRUST 2006-AR1 shall be LOAN TRUST 2006-AR5 shall be LOAN TRUST 2006-AR6 shall be LOAN TRUST 2006-AR7 shall be LOAN TRUST 2006-AR9 shall be LOAN TRUST 2006-CB3 shall be LOAN TRUST 2006-FX1 shall be LOAN TRUST 2006-HE1 shall be LOAN TRUST 2006-HE2 shall be LOAN TRUST 2006-HE3 shall be Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 100 of 157 PagelD #: 1282 1078. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-NC1 shall be designated as Defendant No. 1 186. 1079. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-NC2 shall be designated as Defendant No. 1 187. 1080. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WF1 shall be designated as Defendant No. 1 188. 1081. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WF2 shall be designated as Defendant No. 1 189. 1082. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE1, ASSET- BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WFHE1 shall be designated as Defendant No. 1 190. 1083. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE2 shall be designated as Defendant No. 1191. 1084. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE3 shall be designated as Defendant No. 1 192. 1085. Defendant CITIGROUP MORTGAGE LOAN TRUST 2006-WFHE4 shall be designated as Defendant No. 1 193. 1086. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 194. 1087. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 195. 1088. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 196. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 101 of 157 PagelD #: 1283 1089. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 197. 1090. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-10 shall be designated as Defendant No. 1 198. 1091. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-2 shall be designated as Defendant No. 1 199. 1092. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-6 shall be designated as Defendant No. 1200. 1093. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-6 shall be designated as Defendant No. 1201. 1094. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-8 shall be designated as Defendant No. 1202. 1095. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AHL1 shall be designated as Defendant No. 1203. 1096. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AHL2 shall be designated as Defendant No. 1204. 1097. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AHL3 shall be designated as Defendant No. 1205. 1098. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AMC1 shall be designated as Defendant No. 1206. 1099. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AMC2 shall be designated as Defendant No. 1207. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 102 of 157 PagelD #: 1284 1100. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AMC3 shall be designated as Defendant No. 1208. 1101. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AMC4 shall be designated as Defendant No. 1209. 1102. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AR1 shall be designated as Defendant No. 1210. 1103. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AR4 shall be designated as Defendant No. 121 1. 1104. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-AR5 shall be designated as Defendant No. 1212. 1105. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-CB3 shall be designated as Defendant No. 1213. 1106. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-OPX1 shall be designated as Defendant No. 1214. 1107. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE1 shall be designated as Defendant No. 1215. 1108. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE2 shall be designated as Defendant No. 1216. 1109. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE3 shall be designated as Defendant No. 1217. 1110. Defendant CITIGROUP MORTGAGE LOAN TRUST 2007-WFHE4 shall be designated as Defendant No. 1218. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 103 of 157 PagelD #: 1285 1111. Defendant CITIGROUP MORTGAGE LOAN TRUST INC shall be designated as Defendant No. 1219. 1112. Defendant CITIGROUP MORTGAGE LOAN TRUST INC CARRINGTON MORTGAGE LOAN TRUST, SERIES 2004-NC2 shall be designated as Defendant No. 1220. 1113. Defendant CITIGROUP MORTGAGE LOAN TRUST INC C-BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2004-CB7 shall be designated as Defendant No. 1221. 1 1 14. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-HYB3 shall be designated as Defendant No. 1222. 1115. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004- NCM2 shall be designated as Defendant No. 1223. 1116. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-OPT1 shall be designated as Defendant No. 1224. 1117. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-UST1 shall be designated as Defendant No. 1225. 1118. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2004-UST1 shall be designated as Defendant No. 1226. 1 119. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2005-OPT1 shall be designated as Defendant No. 1227. 1120. Defendant CITIGROUP MORTGAGE LOAN TRUST INC SERIES 2005-OPT2 shall be designated as Defendant No. 1228. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 104 of 157 PagelD #: 1286 1121. Defendant CITIGROUP MORTGAGE LOAN TRUST INC, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-1 shall be designated as Defendant No. 1229. 1122. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. 2005-4 shall be designated as Defendant No. 1230. 1123. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. 2005-7 shall be designated as Defendant No. 1231. 1124. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1232. 1125. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1233. 1126. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1234. 1127. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1235. 1128. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-NCM1 shall be designated as Defendant No. 1236. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 105 of 157 PagelD #: 1287 1129. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1237. 1130. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2005-2 shall be designated as Defendant No. 1238. 1131. Defendant CITIGROUP MORTGAGE LOAN TRUST INC. SERIES 2004 - HYB4 shall be designated as Defendant No. 1239. 1132. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES 2006-WMC1 shall be designated as Defendant No. 1240. 1133. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-3 shall be designated as Defendant No. 1241. 1134. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-3 shall be designated as Defendant No. 1242. 1135. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-5 shall be designated as Defendant No. 1243. 1136. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-8 shall be designated as Defendant No. 1244. 1137. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-9 shall be designated as Defendant No. 1245. 1138. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-HE3 shall be designated as Defendant No. 1246. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 106 of 157 PagelD #: 1288 1139. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2005-HE4 shall be designated as Defendant No. 1247. 1 140. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR2 shall be designated as Defendant No. 1248. 1 141. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR3 shall be designated as Defendant No. 1249. 1 142. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2006-AR3 shall be designated as Defendant No. 1250. 1 143. Defendant CITIGROUP MORTGAGE LOAN TRUST INC., SERIES 2007-AR7 shall be designated as Defendant No. 1251. 1144. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2003 UST-1 shall be designated as Defendant No. 1252. 1145. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-CB3 shall be designated as Defendant No. 1253. 1146. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-HYB1 shall be designated as Defendant No. 1254. 1147. Defendant CITIGROUP MORTGAGE LOAN TRUST SERIES 2004-HYB2 shall be designated as Defendant No. 1255. 1 148. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2004-RES1 shall be designated as Defendant No. 1256. 1 149. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-10 shall be designated as Defendant No. 1257. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 107 of 157 PagelD #: 1289 1150. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-CB4 shall be designated as Defendant No. 1258. 1151. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-CB8, C- BASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES shall be designated as Defendant No. 1259. 1152. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-OPT3 shall be designated as Defendant No. 1260. 1153. Defendant CITIGROUP MORTGAGE LOAN TRUST, SERIES 2005-OPT4 shall be designated as Defendant No. 1261. 1154. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A1 shall be designated as Defendant No. 1262. 1155. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A2 shall be designated as Defendant No. 1263. 1156. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A3 shall be designated as Defendant No. 1264. 1157. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A4 shall be designated as Defendant No. 1265. 1158. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A5 shall be designated as Defendant No. 1266. 1159. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A6 shall be designated as Defendant No. 1267. 1160. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2006-A7 shall be designated as Defendant No. 1268. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 108 of 157 PagelD #: 1290 1161. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A1 shall be designated as Defendant No. 1269. 1162. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A2 shall be designated as Defendant No. 1270. 1163. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A2 shall be designated as Defendant No. 1271. 1164. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A3 shall be designated as Defendant No. 1272. 1165. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A4 shall be designated as Defendant No. 1273. 1166. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A5 shall be designated as Defendant No. 1274. 1167. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A6 shall be designated as Defendant No. 1275. 1168. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A7 shall be designated as Defendant No. 1276. 1169. Defendant CMALT (CITIMORTGAGE ALTERNATIVE LOAN TRUST), SERIES 2007-A8 shall be designated as Defendant No. 1277. 1170. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC shall be designated as Defendant No. 1278. 1171. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC., HOMEBANC MORTGAGE TRUST 2004-2 shall be designated as Defendant No. 1279. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 109 of 157 PagelD #: 1291 1172. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR4 shall be designated as Defendant No. 1280. 1173. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR6 shall be designated as Defendant No. 1281. 1174. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR7 shall be designated as Defendant No. 1282. 1175. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR8 shall be designated as Defendant No. 1283. 1176. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005- AR2 shall be designated as Defendant No. 1284. 1177. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1285. 1178. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1286. 1179. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1287. 1180. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR3 shall be designated as Defendant No. 1288. 1181. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR5 shall be designated as Defendant No. 1289. 1182. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR6 shall be designated as Defendant No. 1290. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 110 of 157 PagelD #: 1292 1183. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1291. 1184. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1292. 1185. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR8 shall be designated as Defendant No. 1293. 1186. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F1 shall be designated as Defendant No. 1294. 1187. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F2 shall be designated as Defendant No. 1295. 1188. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F3 shall be designated as Defendant No. 1296. 1189. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005- F3 shall be designated as Defendant No. 1297. 1190. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1298. 1191. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1299. 1192. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR1 shall be designated as Defendant No. 1300. 1193. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1301. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 111 of 157 PagelD #: 1293 1194. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1302. 1195. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1303. 1196. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1304. 1197. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1305. 1198. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1306. 1199. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1307. 1200. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1308. 1201. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1309. 1202. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1310. 1203. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR6 shall be designated as Defendant No. 13 1 1 . 1204. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1312. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 112 of 157 PagelD #: 1294 1205. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR8 shall be designated as Defendant No. 1313. 1206. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007- AR1 shall be designated as Defendant No. 1314. 1207. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR2 shall be designated as Defendant No. 1315. 1208. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1316. 1209. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1317. 1210. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1318. 1211. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1319. 1212. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1320. 1213. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1321. 1214. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1322. 1215. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1323. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 113 of 157 PagelD #: 1295 1216. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR7 shall be designated as Defendant No. 1324. 1217. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST SERIES 2004-AR3 shall be designated as Defendant No. 1325. 1218. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST SERIES 2005-AR1 shall be designated as Defendant No. 1326. 1219. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1327. 1220. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1328. 1221. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1329. 1222. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1330. 1223. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1331. 1224. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1332. 1225. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS INC shall be designated as Defendant No. 1333. 1226. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS TRUST 2003 AR3 shall be designated as Defendant No. 1334. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 114 of 157 PagelD #: 1296 1227. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS TRUST 2003-AR1 shall be designated as Defendant No. 1335. 1228. Defendant SG MORTGAGE SECURITIES TRUST 2005-OPT1 shall be designated as Defendant No. 1336. 1229. Defendant SG MORTGAGE SECURITIES TRUST 2006-FRE1 shall be designated as Defendant No. 1337. 1230. Defendant SG MORTGAGE SECURITIES TRUST 2006-FRE2 shall be designated as Defendant No. 1338. 1231. Defendant SG MORTGAGE SECURITIES TRUST 2006-OPT2 shall be designated as Defendant No. 1339. 1232. Defendant SG MORTGAGE SECURITIES, LLC shall be designated as Defendant No. 1340. 1233. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR1 shall be designated as Defendant No. 1341. 1234. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR1 1 shall be designated as Defendant No. 1342. 1235. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR12 shall be designated as Defendant No. 1343. 1236. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR13 shall be designated as Defendant No. 1344. 1237. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR14 shall be designated as Defendant No. 1345. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 115 of 157 PagelD #: 1297 1238. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR15 shall be designated as Defendant No. 1346. 1239. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR2 shall be designated as Defendant No. 1347. 1240. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR3 shall be designated as Defendant No. 1348. 1241. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR4 shall be designated as Defendant No. 1349. 1242. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR5 shall be designated as Defendant No. 1350. 1243. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR6 shall be designated as Defendant No. 1351. 1244. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR7 shall be designated as Defendant No. 1352. 1245. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR8 shall be designated as Defendant No. 1353. 1246. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2004-AR9 shall be designated as Defendant No. 1354. 1247. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 1355. 1248. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR10 shall be designated as Defendant No. 1356. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 116 of 157 PagelD #: 1298 1249. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR1 1 shall be designated as Defendant No. 1357. 1250. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR12 shall be designated as Defendant No. 1358. 1251. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR13 shall be designated as Defendant No. 1359. 1252. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR14 shall be designated as Defendant No. 1360. 1253. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR15 shall be designated as Defendant No. 1361. 1254. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR16IP shall be designated as Defendant No. 1362. 1255. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR17 shall be designated as Defendant No. 1363. 1256. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR18 shall be designated as Defendant No. 1364. 1257. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR19 shall be designated as Defendant No. 1365. 1258. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR2 shall be designated as Defendant No. 1366. 1259. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR21 shall be designated as Defendant No. 1367. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 117 of 157 PagelD #: 1299 1260. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR23 shall be designated as Defendant No. 1368. 1261. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR25 shall be designated as Defendant No. 1369. 1262. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR27 shall be designated as Defendant No. 1370. 1263. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR29 shall be designated as Defendant No. 1371. 1264. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR3 shall be designated as Defendant No. 1372. 1265. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR31 shall be designated as Defendant No. 1373. 1266. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR33 shall be designated as Defendant No. 1374. 1267. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR35 shall be designated as Defendant No. 1375. 1268. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR4 shall be designated as Defendant No. 1376. 1269. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR5 shall be designated as Defendant No. 1377. 1270. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR6 shall be designated as Defendant No. 1378. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 118 of 157 PagelD #: 1300 1271. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR7 shall be designated as Defendant No. 1379. 1272. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR8 shall be designated as Defendant No. 1380. 1273. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2005-AR9 shall be designated as Defendant No. 1381. 1274. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR1 1 shall be designated as Defendant No. 1382. 1275. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR12 shall be designated as Defendant No. 1383. 1276. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR13 shall be designated as Defendant No. 1384. 1277. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR14 shall be designated as Defendant No. 1385. 1278. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR15 shall be designated as Defendant No. 1386. 1279. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR19 shall be designated as Defendant No. 1387. 1280. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR2 shall be designated as Defendant No. 1388. 1281. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR21 shall be designated as Defendant No. 1389. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 119 of 157 PagelD #: 1301 1282. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR23 shall be designated as Defendant No. 1390. 1283. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR25 shall be designated as Defendant No. 1391. 1284. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR27 shall be designated as Defendant No. 1392. 1285. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR27 shall be designated as Defendant No. 1393. 1286. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR29 shall be designated as Defendant No. 1394. 1287. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR3 shall be designated as Defendant No. 1395. 1288. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR31 shall be designated as Defendant No. 1396. 1289. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR33 shall be designated as Defendant No. 1397. 1290. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR35 shall be designated as Defendant No. 1398. 1291. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR37 shall be designated as Defendant No. 1399. 1292. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR39 shall be designated as Defendant No. 1400. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 120 of 157 PagelD #: 1302 1293. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR4 shall be designated as Defendant No. 1401. 1294. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR41 shall be designated as Defendant No. 1402. 1295. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR5 shall be designated as Defendant No. 1403. 1296. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR6 shall be designated as Defendant No. 1404. 1297. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR7 shall be designated as Defendant No. 1405. 1298. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR8 shall be designated as Defendant No. 1406. 1299. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-AR9 shall be designated as Defendant No. 1407. 1300. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-FLX1 shall be designated as Defendant No. 1408. 1301. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2006-R1 shall be designated as Defendant No. 1409. 1302. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR1 shall be designated as Defendant No. 1410. 1303. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR1 1 shall be designated as Defendant No. 141 1. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 121 of 157 PagelD #: 1303 1304. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR13 shall be designated as Defendant No. 1412. 1305. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR15 shall be designated as Defendant No. 1413. 1306. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR17 shall be designated as Defendant No. 1414. 1307. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR19 shall be designated as Defendant No. 1415. 1308. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR21IP shall be designated as Defendant No. 1416. 1309. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR5 shall be designated as Defendant No. 1417. 1310. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR7 shall be designated as Defendant No. 1418. 1311. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-AR9 shall be designated as Defendant No. 1419. 1312. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX1 shall be designated as Defendant No. 1420. 1313. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX2 shall be designated as Defendant No. 1421. 1314. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX2 shall be designated as Defendant No. 1422. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 122 of 157 PagelD #: 1304 1315. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX3 shall be designated as Defendant No. 1423. 1316. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX4 shall be designated as Defendant No. 1424. 1317. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX5 shall be designated as Defendant No. 1425. 1318. Defendant INDYMAC INDX MORTGAGE LOAN TRUST 2007-FLX6 shall be designated as Defendant No. 1426. 1319. Defendant GMAC MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-AR1 shall be designated as Defendant No. 1427. 1320. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1428. 1321. Defendant GMACM HOME EQUITY LOAN BACKED NOTES SERIES 2002- HE4 shall be designated as Defendant No. 1429. 1322. Defendant GMACM HOME EQUITY LOAN BACKED TERM NOTES SER 2003-HE1 shall be designated as Defendant No. 1430. 1323. Defendant GMACM HOME EQUITY LOAN BACKED TERM NOTES SERIES 2000-HE4 shall be designated as Defendant No. 1431. 1324. Defendant GMACM HOME EQUITY LOAN TRUST 2003-HE2 shall be designated as Defendant No. 1432. 1325. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE3 shall be designated as Defendant No. 1433. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 123 of 157 PagelD #: 1305 1326. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE4 shall be designated as Defendant No. 1434. 1327. Defendant GMACM HOME EQUITY LOAN TRUST 2004-HE5 shall be designated as Defendant No. 1435. 1328. Defendant GMACM HOME EQUITY LOAN TRUST 2005-HE1 shall be designated as Defendant No. 1436. 1329. Defendant GMACM HOME EQUITY LOAN TRUST 2005-HE2 shall be designated as Defendant No. 1437. 1330. Defendant GMACM HOME EQUITY LOAN TRUST 2005-HE3 shall be designated as Defendant No. 1438. 1331. Defendant GMACM HOME EQUITY LOAN TRUST 2006-HE5 shall be designated as Defendant No. 1439. 1332. Defendant GMACM HOME EQUITY LOAN-BACKED NOTES SERIES 2001- HE1 shall be designated as Defendant No. 1440. 1333. Defendant GMACM HOME EQUITY LOAN-BACKED TERM NOTES SERIES 2001-HE2 shall be designated as Defendant No. 1441. 1334. Defendant GMACM HOME EQUITY LOAN-BACKED TERM NOTES SERIES 2001-HE3 shall be designated as Defendant No. 1442. 1335. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2000- CL1 shall be designated as Defendant No. 1443. 1336. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2000- HLTV2 shall be designated as Defendant No. 1444. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 124 of 157 PagelD #: 1306 1337. Defendant GMACM HOME LOAN BACKED TERM NOTES SERIES 2002- HLTV1 shall be designated as Defendant No. 1445. 1338. Defendant GMACM HOME LOAN TRUST 2004-HLTV1 shall be designated as Defendant No. 1446. 1339. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- CL1 shall be designated as Defendant No. 1447. 1340. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- HLTV1 shall be designated as Defendant No. 1448. 1341. Defendant GMACM HOME LOAN-BACKED TERM NOTES SERIES 2001- HLTV2 shall be designated as Defendant No. 1449. 1342. Defendant GMACM MORTGAGE LOAN BACKED NOTES SERIES 2000- HE3 shall be designated as Defendant No. 1450. 1343. Defendant GMACM MORTGAGE LOAN TRUST 2003-J7 shall be designated as Defendant No. 145 1 . 1344. Defendant GMACM MORTGAGE LOAN TRUST 2004-GH1 shall be designated as Defendant No. 1452. 1345. Defendant GMACM MORTGAGE LOAN TRUST 2005-AA1 shall be designated as Defendant No. 1453. 1346. Defendant GMACM MORTGAGE LOAN TRUST 2005-AF1 shall be designated as Defendant No. 1454. 1347. Defendant GMACM MORTGAGE LOAN TRUST 2005-AF2 shall be designated as Defendant No. 1455. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 125 of 157 PagelD #: 1307 1348. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 1456. 1349. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR1 shall be designated as Defendant No. 1457. 1350. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR2 shall be designated as Defendant No. 1458. 1351. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR3 shall be designated as Defendant No. 1459. 1352. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR4 shall be designated as Defendant No. 1460. 1353. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR5 shall be designated as Defendant No. 1461. 1354. Defendant GMACM MORTGAGE LOAN TRUST 2005-AR6 shall be designated as Defendant No. 1462. 1355. Defendant GMACM MORTGAGE LOAN TRUST 2005-J1 shall be designated as Defendant No. 1463. 1356. Defendant GMACM MORTGAGE PASS THRU CERTS SERIES 2003-J8 shall be designated as Defendant No. 1464. 1357. Defendant GMACM MORTGAGE PASS-THROUGH CERIFICATES, SERIES 2004-J5 shall be designated as Defendant No. 1465. 1358. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2003-J5 shall be designated as Defendant No. 1466. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 126 of 157 PagelD #: 1308 1359. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2004-AR2 shall be designated as Defendant No. 1467. 1360. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J2 shall be designated as Defendant No. 1468. 1361. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J3 shall be designated as Defendant No. 1469. 1362. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J4 shall be designated as Defendant No. 1470. 1363. Defendant GMACM MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-J6 shall be designated as Defendant No. 1471. 1364. Defendant RAAC SERIES 2004-SP1 TRUST shall be designated as Defendant No. 1472. 1365. Defendant RAAC SERIES 2004-SP2 shall be designated as Defendant No. 1473. 1366. Defendant RAAC SERIES 2004-SP3 shall be designated as Defendant No. 1474. 1367. Defendant RAAC SERIES 2005-SP1 TRUST shall be designated as Defendant No. 1475. 1368. Defendant RAAC SERIES 2005-SP3 TRUST shall be designated as Defendant No. 1476. 1369. Defendant RAAC SERIES 2007 SP2 TRUST shall be designated as Defendant No. 1477. 1370. Defendant RAAC SERIES 2007-SP1 TRUST shall be designated as Defendant No. 1478. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 127 of 157 PagelD #: 1309 1371. Defendant RAAC SERIES 2007-SP3 TRUST shall be designated as Defendant No. 1479. 1372. Defendant RAAC SERIES 2007-SP3 TRUST shall be designated as Defendant No. 1480. 1373. Defendant RAMP SERIES 2004-R12 TRUST shall be designated as Defendant No. 1481. 1374. Defendant RAMP SERIES 2004-RS1 TRUST shall be designated as Defendant No. 1482. 1375. Defendant RAMP SERIES 2004-RS1 TRUST shall be designated as Defendant No. 1483. 1376. Defendant RAMP SERIES 2004-RS10 TRUST shall be designated as Defendant No. 1484. 1377. Defendant RAMP SERIES 2004-RS11 TRUST shall be designated as Defendant No. 1485. 1378. Defendant RAMP SERIES 2004-RS2 TRUST shall be designated as Defendant No. 1486. 1379. Defendant RAMP SERIES 2004-RS4 TRUST shall be designated as Defendant No. 1487. 1380. Defendant RAMP SERIES 2004-RS5 TRUS shall be designated as Defendant No. 1488. 1381. Defendant RAMP SERIES 2004-RS6 TRUST shall be designated as Defendant No. 1489. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 128 of 157 PagelD #: 1310 1382. Defendant RAMP SERIES 2004-RS7 TRUST shall be designated as Defendant No. 1490. 1383. Defendant RAMP SERIES 2004-RS8 TRUST shall be designated as Defendant No. 1491. 1384. Defendant RAMP SERIES 2004-RS9 TRUST shall be designated as Defendant No. 1492. 1385. Defendant RAMP SERIES 2004-RZ2 TRUST shall be designated as Defendant No. 1493. 1386. Defendant RAMP SERIES 2004-RZ3 TRUST shall be designated as Defendant No. 1494. 1387. Defendant RAMP SERIES 2004-RZ3 TRUST shall be designated as Defendant No. 1495. 1388. Defendant RAMP SERIES 2004-RZ4 TRUST shall be designated as Defendant No. 1496. 1389. Defendant RAMP SERIES 2004-SL2 TRUST shall be designated as Defendant No. 1497. 1390. Defendant RAMP SERIES 2004-SL3 TRUST shall be designated as Defendant No. 1498. 1391. Defendant RAMP SERIES 2004-SL4 TRUST shall be designated as Defendant No. 1499. 1392. Defendant RAMP SERIES 2005 SL2 TRUST shall be designated as Defendant No. 1500. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 129 of 157 PagelD #: 1311 1393. Defendant RAMP SERIES 2005-EFC1 TRUST shall be designated as Defendant No. 1501. 1394. Defendant RAMP SERIES 2005-EFC2 shall be designated as Defendant No. 1502. 1395. Defendant RAMP SERIES 2005-EFC3 TRUST shall be designated as Defendant No. 1503. 1396. Defendant RAMP SERIES 2005-EFC4 TRUST shall be designated as Defendant No. 1504. 1397. Defendant RAMP SERIES 2005-EFC5 TRUST shall be designated as Defendant No. 1505. 1398. Defendant RAMP SERIES 2005-EFC6 TRUST shall be designated as Defendant No. 1506. 1399. Defendant RAMP SERIES 2005-RS2 TRUST shall be designated as Defendant No. 1507. 1400. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1508. 1401. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1509. 1402. Defendant RAMP SERIES 2005-RS4 TRUST shall be designated as Defendant No. 1510. 1403. Defendant RAMP SERIES 2005-RS5 TRUST shall be designated as Defendant No. 1511. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 130 of 157 PagelD #: 1312 1404. Defendant RAMP SERIES 2005-RS6 TRUST shall be designated as Defendant No. 1512. 1405. Defendant RAMP SERIES 2005-RS7 TRUST shall be designated as Defendant No. 1513. 1406. Defendant RAMP SERIES 2005-RS8 TRUST shall be designated as Defendant No. 1514. 1407. Defendant RAMP SERIES 2005-RS9 TRUST shall be designated as Defendant No. 1515. 1408. Defendant RAMP SERIES 2005-RZ1 TRUST shall be designated as Defendant No. 1516. 1409. Defendant RAMP SERIES 2005-RZ2 TRUST shall be designated as Defendant No. 1517. 1410. Defendant RAMP SERIES 2005-RZ3 TRUST shall be designated as Defendant No. 1518. 1411. Defendant RAMP SERIES 2005-RZ4 TRUST shall be designated as Defendant No. 1519. 1412. Defendant RAMP SERIES 2005-SL1 TRUST shall be designated as Defendant No. 1520. 1413. Defendant RAMP SERIES 2005-SP2 TRUST shall be designated as Defendant No. 1521. 1414. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1522. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 131 of 157 PagelD #: 1313 1415. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1523. 1416. Defendant RAMP SERIES 2006-SP1 TRUST shall be designated as Defendant No. 1524. 1417. Defendant RESIDENTIAL ASSET BACKED PASS THR CERTS SER 2003- RS4 shall be designated as Defendant No. 1525. 1418. Defendant RESIDENTIAL ASSET GMACM MORTGAGE LOAN TRUST 2004-JR1 shall be designated as Defendant No. 1526. 1419. Defendant RESIDENTIAL ASSET MOR PRO INC GMACM MO PASS TH CE SE 2006 J6 shall be designated as Defendant No. 1527. 1420. Defendant RESIDENTIAL ASSET MORT PRO INC GMACM MO PA TH CE SE 03 AR2 shall be designated as Defendant No. 1528. 1421. Defendant RESIDENTIAL ASSET MORT PROD GMACM PS THR CERTS SER 2003-J4 shall be designated as Defendant No. 1529. 1422. Defendant RESIDENTIAL ASSET MORT PROD INC GMACH HM EQ LN TR 2002-HE1 shall be designated as Defendant No. 1530. 1423. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ L N TR 04 HE2 shall be designated as Defendant No. 153 1 . 1424. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE1 shall be designated as Defendant No. 1532. 1425. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE2 shall be designated as Defendant No. 1533. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 132 of 157 PagelD #: 1314 1426. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1534. 1427. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1535. 1428. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2004 HE1 shall be designated as Defendant No. 1536. 1429. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM MORT LN TR 03 -J2 shall be designated as Defendant No. 1537. 1430. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 RZ1 TRUST shall be designated as Defendant No. 1538. 1431. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 SL1 TRUST shall be designated as Defendant No. 1539. 1432. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LN TR 03 GH2 shall be designated as Defendant No. 1540. 1433. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LOAN TR 03 J10 shall be designated as Defendant No. 1541. 1434. Defendant RESIDENTIAL ASSET MORT PRODUCT GMACM LOAN SER 2003-AR1 shall be designated as Defendant No. 1542. 1435. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03 J3 shall be designated as Defendant No. 1543. 1436. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03-J1 shall be designated as Defendant No. 1544. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 133 of 157 PagelD #: 1315 1437. Defendant RESIDENTIAL ASSET MORTGAGE PROD INC GMACM MOR LN TR 2003-GH1 shall be designated as Defendant No. 1545. 1438. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS GMACM TRUST 2004-J1 shall be designated as Defendant No. 1546. 1439. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1547. 1440. Defendant RAMP SERIES 2005-RS3 TRUST shall be designated as Defendant No. 1548. 1441. Defendant RAMP SERIES 2005-RS4 TRUST shall be designated as Defendant No. 1549. 1442. Defendant RAMP SERIES 2005-RS5 TRUST shall be designated as Defendant No. 1550. 1443. Defendant RAMP SERIES 2005-RS6 TRUST shall be designated as Defendant No. 1551. 1444. Defendant RAMP SERIES 2005-RS7 TRUST shall be designated as Defendant No. 1552. 1445. Defendant RAMP SERIES 2005-RS8 TRUST shall be designated as Defendant No. 1553. 1446. Defendant RAMP SERIES 2005-RS9 TRUST shall be designated as Defendant No. 1554. 1447. Defendant RAMP SERIES 2005-RZ1 TRUST shall be designated as Defendant No. 1555. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 134 of 157 PagelD #: 1316 1448. Defendant RAMP SERIES 2005-RZ2 TRUST shall be designated as Defendant No. 1556. 1449. Defendant RAMP SERIES 2005-RZ3 TRUST shall be designated as Defendant No. 1557. 1450. Defendant RAMP SERIES 2005-RZ4 TRUST shall be designated as Defendant No. 1558. 1451. Defendant RAMP SERIES 2005-SL1 TRUST shall be designated as Defendant No. 1559. 1452. Defendant RAMP SERIES 2005-SP2 TRUST shall be designated as Defendant No. 1560. 1453. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1561. 1454. Defendant RAMP SERIES 2006-RS2 TRUST shall be designated as Defendant No. 1562. 1455. Defendant RAMP SERIES 2006-SP1 TRUST shall be designated as Defendant No. 1563. 1456. Defendant RESIDENTIAL ASSET BACKED PASS THR CERTS SER 2003- RS4 shall be designated as Defendant No. 1564. 1457. Defendant RESIDENTIAL ASSET GMACM MORTGAGE LOAN TRUST 2004-JR1 shall be designated as Defendant No. 1565. 1458. Defendant RESIDENTIAL ASSET MOR PRO INC GMACM MO PASS TH CE SE 2006 J6 shall be designated as Defendant No. 1566. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 135 of 157 PagelD #: 1317 1459. Defendant RESIDENTIAL ASSET MORT PRO INC GMACM MO PA TH CE SE 03 AR2 shall be designated as Defendant No. 1567. 1460. Defendant RESIDENTIAL ASSET MORT PROD GMACM PS THR CERTS SER 2003-J4 shall be designated as Defendant No. 1568. 1461 . Defendant RESIDENTIAL ASSET MORT PROD INC GMACH HM EQ LN TR 2002-HE1 shall be designated as Defendant No. 1569. 1462. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ L N TR 04 HE2 shall be designated as Defendant No. 1570. 1463. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE1 shall be designated as Defendant No. 1571. 1464. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2000 HE2 shall be designated as Defendant No. 1572. 1465. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1573. 1466. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2001 HE4 shall be designated as Defendant No. 1574. 1467. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM HOME EQ LN TR 2004 HE1 shall be designated as Defendant No. 1575. 1468. Defendant RESIDENTIAL ASSET MORT PROD INC GMACM MORT LN TR 03 -J2 shall be designated as Defendant No. 1576. 1469. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 RZ1 TRUST shall be designated as Defendant No. 1577. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 136 of 157 PagelD #: 1318 1470. Defendant RESIDENTIAL ASSET MORT PROD INC RAMP SERIES 2004 SL1 TRUST shall be designated as Defendant No. 1578. 1471. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LN TR 03 GH2 shall be designated as Defendant No. 1579. 1472. Defendant RESIDENTIAL ASSET MORT PRODS INC GMACM MORT LOAN TR 03 J10 shall be designated as Defendant No. 1580. 1473. Defendant RESIDENTIAL ASSET MORT PRODUCT GMACM LOAN SER 2003- AR1 shall be designated as Defendant No. 1581. 1474. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03 J3 shall be designated as Defendant No. 1582. 1475. Defendant RESIDENTIAL ASSET MORT PRODUCTS INC GMACM MORT LN TR 03-J1 shall be designated as Defendant No. 1583. 1476. Defendant RESIDENTIAL ASSET MORTGAGE PROD INC GMACM MOR LN TR 2003-GH1 shall be designated as Defendant No. 1584. 1477. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS GMACM TRUST 2004-J1 shall be designated as Defendant No. 1585. 1478. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC shall be designated as Defendant No. 1586. 1479. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS INC TRUST 2000-HLTV1 shall be designated as Defendant No. 1587. 1480. Defendant RESIDENTIAL ASSET MORTGAGE PRODUCTS RAMP TRUST 2004- RS3 shall be designated as Defendant No. 1588. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 137 of 157 PagelD #: 1319 1481. Defendant RESIDENTIAL ASST MORT PROD GMACM MT PS THR CERTS SER 2003-J9 shall be designated as Defendant No. 1589. 1482. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST SERIES 2007-2 shall be designated as Defendant No. 1590. 1483. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST SERIES 2007-OA5 /DE shall be designated as Defendant No. 1591. 1484. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AF1 shall be designated as Defendant No. 1592. 1485. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR2 shall be designated as Defendant No. 1593. 1486. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR3 shall be designated as Defendant No. 1594. 1487. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR4 shall be designated as Defendant No. 1595. 1488. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR5 shall be designated as Defendant No. 1596. 1489. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AR6 shall be designated as Defendant No. 1597. 1490. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-OA1 shall be designated as Defendant No. 1598. 1491. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-1 shall be designated as Defendant No. 1599. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 138 of 157 PagelD #: 1320 1492. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-1 shall be designated as Defendant No. 1600. 1493. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-3 shall be designated as Defendant No. 1601. 1494. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-AR1 shall be designated as Defendant No. 1602. 1495. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-AR2 shall be designated as Defendant No. 1603. 1496. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-AR2 shall be designated as Defendant No. 1604. 1497. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-AR3 shall be designated as Defendant No. 1605. 1498. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA1 shall be designated as Defendant No. 1606. 1499. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA2 shall be designated as Defendant No. 1607. 1500. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA3 /DE shall be designated as Defendant No. 1608. 1501. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-OA4 /DE shall be designated as Defendant No. 1609. 1502. Defendant DEUTSCHE ALT-A SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-RAMP1 shall be designated as Defendant No. 1610. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 139 of 157 PagelD #: 1321 1503. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-1 shall be designated as Defendant No. 161 1 . 1504. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-2 shall be designated as Defendant No. 1612. 1505. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-3 shall be designated as Defendant No. 1613. 1506. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-4 shall be designated as Defendant No. 1614. 1507. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-5 shall be designated as Defendant No. 1615. 1508. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-6 shall be designated as Defendant No. 1616. 1509. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1617. 1510. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1618. 1511. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1619. 1512. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR2 shall be designated as Defendant No. 1620. 1513. Defendant DEUTSCHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2006-AR1 shall be designated as Defendant No. 1621. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 140 of 157 PagelD #: 1322 1514. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AB1 shall be designated as Defendant No. 1622. 1515. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2006-AB3 shall be designated as Defendant No. 1623. 1516. Defendant DEUTSCHE ALT-B SECURITIES MORTGAGE LOAN TRUST, SERIES 2007-AB1 shall be designated as Defendant No. 1624. 1517. Defendant DEUTSCHE ALT-B SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2006-AB2 shall be designated as Defendant No. 1625. 1518. Defendant DEUTSHE ALT-A SECURITIES, INC. MORTGAGE LOAN TRUST, SERIES 2005-AR1 shall be designated as Defendant No. 1626. 1519. Defendant MORTGAGE LOAN TRUST SERIES 2003-2XS shall be designated as Defendant No. 1627. 1520. Defendant SASCO MORTGAGE LOAN TRUST 2004-GEL3 shall be designated as Defendant No. 1628. 1521. Defendant SASCO MORTGAGE LOAN TRUST 2005-WF3 shall be designated as Defendant No. 1629. 1522. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2003-GEL1 shall be designated as Defendant No. 1630. 1523. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2004-GEL2 shall be designated as Defendant No. 1631. 1524. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL1 shall be designated as Defendant No. 1632. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 141 of 157 PagelD #: 1323 1525. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL2 shall be designated as Defendant No. 1633. 1526. Defendant SASCO MORTGAGE LOAN TRUST SERIES 2005-GEL3 shall be designated as Defendant No. 1634. 1527. Defendant SASCO MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2005-NC1 shall be designated as Defendant No. 1635. 1528. Defendant SASCO MORTGAGE PASS THROUGH CERTIFICATES, SERIES 2005-NC2 shall be designated as Defendant No. 1636. 1529. Defendant SASCO MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004- S4 shall be designated as Defendant No. 1637. 1530. Defendant SASCO MORTGAGE PASS-THROUGH CERTIFID ATE S , SERIES 2005- WMC1 shall be designated as Defendant No. 1638. 1531. Defendant STRUCT ASS MORT INV INC BS ALTA MORT PAS THR CER SER 2003 1 shall be designated as Defendant No. 1639. 1532. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE shall be designated as Defendant No. 1640. 1533. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN RATE shall be designated as Defendant No. 1641. 1534. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1642. 1535. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1643. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 142 of 157 PagelD #: 1324 1536. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1644. 1537. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1645. 1538. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1646. 1539. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1647. 1540. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1648. 1541. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1649. 1542. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1650. 1543. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 165 1 . 1544. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1652. 1545. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST shall be designated as Defendant No. 1653. 1546. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2004-5 shall be designated as Defendant No. 1654. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 143 of 157 PagelD #: 1325 1547. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005-3XS shall be designated as Defendant No. 1655. 1548. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005-6XS shall be designated as Defendant No. 1656. 1549. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST 2005-8XS shall be designated as Defendant No. 1657. 1550. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-14 shall be designated as Defendant No. 1658. 1551. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-15 shall be designated as Defendant No. 1659. 1552. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-16 shall be designated as Defendant No. 1660. 1553. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-17 shall be designated as Defendant No. 1661. 1554. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-12 shall be designated as Defendant No. 1662. 1555. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-15 shall be designated as Defendant No. 1663. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 144 of 157 PagelD #: 1326 1556. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-16XS shall be designated as Defendant No. 1664. 1557. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-17 shall be designated as Defendant No. 1665. 1558. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-18 shall be designated as Defendant No. 1666. 1559. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-2 shall be designated as Defendant No. 1667. 1560. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-20 shall be designated as Defendant No. 1668. 1561. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-20 shall be designated as Defendant No. 1669. 1562. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-21 shall be designated as Defendant No. 1670. 1563. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-22 shall be designated as Defendant No. 1671. 1564. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-23 shall be designated as Defendant No. 1672. 1565. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-4 shall be designated as Defendant No. 1673. 1566. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-7 shall be designated as Defendant No. 1674. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 145 of 157 PagelD #: 1327 1567. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2005-7N shall be designated as Defendant No. 1675. 1568. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-1 shall be designated as Defendant No. 1676. 1569. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-10 shall be designated as Defendant No. 1677. 1570. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-1 1 shall be designated as Defendant No. 1678. 1571. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-12 shall be designated as Defendant No. 1679. 1572. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-2 shall be designated as Defendant No. 1680. 1573. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-3 shall be designated as Defendant No. 1681. 1574. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-4 shall be designated as Defendant No. 1682. 1575. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-5 shall be designated as Defendant No. 1683. 1576. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-6 shall be designated as Defendant No. 1684. 1577. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-7 shall be designated as Defendant No. 1685. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 146 of 157 PagelD #: 1328 1578. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-8 shall be designated as Defendant No. 1686. 1579. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2006-9 shall be designated as Defendant No. 1687. 1580. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-1 shall be designated as Defendant No. 1688. 1581. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-10 shall be designated as Defendant No. 1689. 1582. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-1 1 shall be designated as Defendant No. 1690. 1583. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-2 shall be designated as Defendant No. 1691. 1584. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-3 shall be designated as Defendant No. 1692. 1585. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-4 shall be designated as Defendant No. 1693. 1586. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-5 shall be designated as Defendant No. 1694. 1587. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-6 shall be designated as Defendant No. 1695. 1588. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-7 shall be designated as Defendant No. 1696. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 147 of 157 PagelD #: 1329 1589. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-8 shall be designated as Defendant No. 1697. 1590. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2007-9 shall be designated as Defendant No. 1698. 1591. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2008-1 shall be designated as Defendant No. 1699. 1592. Defendant STRUCTURED ADJUSTABLE RATE MORTGAGE LOAN TRUST SERIES 2008-2 shall be designated as Defendant No. 1700. 1593. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 1 shall be designated as Defendant No. 1701. 1594. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 10 shall be designated as Defendant No. 1702. 1595. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 1 1 shall be designated as Defendant No. 1703. 1596. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 3 shall be designated as Defendant No. 1704. 1597. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 5 shall be designated as Defendant No. 1705. 1598. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 6 shall be designated as Defendant No. 1706. 1599. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 7 shall be designated as Defendant No. 1707. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 148 of 157 PagelD #: 1330 1600. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 8 shall be designated as Defendant No. 1708. 1601. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 04 9 shall be designated as Defendant No. 1709. 1602. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 05 2 shall be designated as Defendant No. 1710. 1603. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ALT A TR 05 3 shall be designated as Defendant No. 1711. 1604. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TR 2004 1 shall be designated as Defendant No. 1712. 1605. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TR 2004 2 shall be designated as Defendant No. 1713. 1606. Defendant STRUCTURED ASSET MORT INV II INC BEAR STEARNS ARM TRUST 03-7 shall be designated as Defendant No. 1714. 1607. Defendant STRUCTURED ASSET MORT INV II INC MORT PAS THR CERT SE 04 CL1 shall be designated as Defendant No. 1715. 1608. Defendant STRUCTURED ASSET MORT INV II INC PRIME MORTGAGE TRUST 2003 2 shall be designated as Defendant No. 1716. 1609. Defendant STRUCTURED ASSET MORT INV II INC THORNBURG MORT SEC TR 03 5 shall be designated as Defendant No. 1717. 1610. Defendant STRUCTURED ASSET MORT INV INC BEAR STEARNS ALT A TR 03 4 shall be designated as Defendant No. 1718. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 149 of 157 PagelD #: 1331 1611. Defendant STRUCTURED ASSET MORT INV INC BEAR STEARNS ARM TRUST 2003 3 shall be designated as Defendant No. 1719. 1612. Defendant STRUCTURED ASSET MORT INV INC MORT BACK NTS SER 2003-1 shall be designated as Defendant No. 1720. 1613. Defendant STRUCTURED ASSET MORT INV INC MORT PAS THR CERTS SER 2003-3 shall be designated as Defendant No. 1721. 1614. Defendant STRUCTURED ASSET MORT INV INC MORT PASS THR CERTS SER 2003-1 shall be designated as Defendant No. 1722. 1615. Defendant STRUCTURED ASSET MORT INV INC THORNBURG MORT SEC TR 2003-2 shall be designated as Defendant No. 1723. 1616. Defendant STRUCTURED ASSET MORT INVEST INC MORT PAS THR CERT SE 03 CL1 shall be designated as Defendant No. 1724. 1617. Defendant STRUCTURED ASSET MORT INVEST INC MORT PAS THR CERTS SER 03 1 shall be designated as Defendant No. 1725. 1618. Defendant STRUCTURED ASSET MORT INVESTMENT THORNBURG SEC TRUST 2004-1 shall be designated as Defendant No. 1726. 1619. Defendant STRUCTURED ASSET MORT PASS THRU CERTS SERIES 2003 AR4 shall be designated as Defendant No. 1727. 1620. Defendant STRUCTURED ASSET MORT PASS THRU CERTS SERIES 2004 AR3 shall be designated as Defendant No. 1728. 1621. Defendant STRUCTURED ASSET MORTGAGE INVEST TRUST 2003-AR2 shall be designated as Defendant No. 1729. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 150 of 157 PagelD #: 1332 1622. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II 2005-AR4 shall be designated as Defendant No. 1730. 1623. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC shall be designated as Defendant No. 1731. 1624. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II INC., HOMEBANC MORTGAGE TRUST 2004-2 shall be designated as Defendant No. 1732. 1625. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II SERIES 2004-AR5 shall be designated as Defendant No. 1733. 1626. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR4 shall be designated as Defendant No. 1734. 1627. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR6 shall be designated as Defendant No. 1735. 1628. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004-AR7 shall be designated as Defendant No. 1736. 1629. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2004- AR8 shall be designated as Defendant No. 1737. 1630. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005 - AR2 shall be designated as Defendant No. 1738. 1631. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR2 shall be designated as Defendant No. 1739. 1632. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005 -AR2 shall be designated as Defendant No. 1740. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 151 of 157 PagelD #: 1333 1633. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR3 shall be designated as Defendant No. 1741. 1634. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR5 shall be designated as Defendant No. 1742. 1635. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR6 shall be designated as Defendant No. 1743. 1636. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1744. 1637. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR7 shall be designated as Defendant No. 1745. 1638. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-AR8 shall be designated as Defendant No. 1746. 1639. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F1 shall be designated as Defendant No. 1747. 1640. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F2 shall be designated as Defendant No. 1748. 1641. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005-F3 shall be designated as Defendant No. 1749. 1642. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2005- F3 shall be designated as Defendant No. 1750. 1643. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR1 shall be designated as Defendant No. 1751. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 152 of 157 PagelD #: 1334 1644. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1752. 1645. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1753. 1646. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR2 shall be designated as Defendant No. 1754. 1647. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1755. 1648. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR3 shall be designated as Defendant No. 1756. 1649. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1757. 1650. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR4 shall be designated as Defendant No. 1758. 1651. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1759. 1652. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1760. 1653. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR5 shall be designated as Defendant No. 1761. 1654. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR6 shall be designated as Defendant No. 1762. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 153 of 157 PagelD #: 1335 1655. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1763. 1656. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006-AR7 shall be designated as Defendant No. 1764. 1657. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006- AR8 shall be designated as Defendant No. 1765. 1658. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1766. 1659. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2006AR1 shall be designated as Defendant No. 1767. 1660. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007- AR1 shall be designated as Defendant No. 1768. 1661. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR2 shall be designated as Defendant No. 1769. 1662. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1770. 1663. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR3 shall be designated as Defendant No. 1771. 1664. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1772. 1665. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR4 shall be designated as Defendant No. 1773. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 154 of 157 PagelD #: 1336 1666. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1774. 1667. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR5 shall be designated as Defendant No. 1775. 1668. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1776. 1669. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR6 shall be designated as Defendant No. 1777. 1670. Defendant STRUCTURED ASSET MORTGAGE INVESTMENTS II TRUST 2007-AR7 shall be designated as Defendant No. 1778. 1671. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2006-BC5 shall be designated as Defendant No. 1779. 1672. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2006-BC6 shall be designated as Defendant No. 1780. 1673. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC2 shall be designated as Defendant No. 1781. 1674. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC3 shall be designated as Defendant No. 1782. 1675. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-BC4 shall be designated as Defendant No. 1783. 1676. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-OSI shall be designated as Defendant No. 1784. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 155 of 157 PagelD #: 1337 1677. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-WF1 shall be designated as Defendant No. 1785. 1678. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE LOAN TRUST 2007-WF2 shall be designated as Defendant No. 1786. 1679. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004-1 1XS shall be designated as Defendant No. 1787. 1680. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004-9XS shall be designated as Defendant No. 1788. 1681. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES 2004-S2 shall be designated as Defendant No. 1789. 1682. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-10 shall be designated as Defendant No. 1790. 1683. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-13 shall be designated as Defendant No. 1791. 1684. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-15 shall be designated as Defendant No. 1792. 1685. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-16XS shall be designated as Defendant No. 1793. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 156 of 157 PagelD #: 1338 1686. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-17XS shall be designated as Defendant No. 1794. 1687. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-19-XS shall be designated as Defendant No. 1795. 1688. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-20 shall be designated as Defendant No. 1796. 1689. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-2 1XS shall be designated as Defendant No. 1797. 1690. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-22 shall be designated as Defendant No. 1798. 1691. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-23XS shall be designated as Defendant No. 1799. 1692. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-7 shall be designated as Defendant No. 1800. Case l:12-cv-04269-JBW-RML Document 36-2 Filed 10/25/12 Page 157 of 157 PagelD #: 1339 1693. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-1 shall be designated as Defendant No. 1801. 1694. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-10 shall be designated as Defendant No. 1802. 1695. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-1 1H shall be designated as Defendant No. 1803. 1696. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-2XS shall be designated as Defendant No. 1804. 1697. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-WF1 shall be designated as Defendant No. 1805. 1698. Defendant STRUCTURED ASSET SECURITIES CORP MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2005-WF2 shall be designated as Defendant No. 1806. 1699. Defendant STRUCTURED ASSET SECURITIES CORP. MORTGAGE LOAN TRUST 2005-7XS shall be designated as Defendant No. 1807. 1700. Defendant STRUCTURES ASSET MORT PRIME MORT TR PAS THR CER SER 2004 CL2 shall be designated as Defendant No. 1808. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 1 of 339 PagelD #: 1340 United States Senate PERMANENT SUBCOMMITTEE ON INVESTIGATIONS Committee on Homeland Security and Governmental Affairs Carl Levin, Chairman Tom Coburn, Ranking Minority Member U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History MAJORITY AND MINORITY STAFF REPORT PERMANENT SUBCOMMITTEE ON INVESTIGATIONS UNITED STATES SENATE RELEASED IN CONJUNCTION WITH THE PERMANENT SUBCOMMITTEE ON INVESTIGATIONS JULY 17, 2012 HEARING Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 2 of 339 PagelD #: 1341 SENATOR CARL LEVIN Chairman SENATOR TOM COBURN, M.D. Ranking Minority Member PERMANENT SUBCOMMITTEE ON INVESTIGATIONS ELISE J. BEAN Staff Director and Chief Counsel ROBERT L. ROACH Counsel and Chief Investigator LAURA E. STUBER Senior Counsel ALLISON ABRAMS Detailee ERIC WALKER Detailee KRISTIN GWIN Congressional Fellow BRIAN EGGER Detailee ADAM C. HENDERSON Professional Staff Member CHRISTOPHER J. BARKLEY Staff Director to the Minority KEITH B. ASHDOWN Chief Investigator to the Minority JUSTIN J. ROOD Senior Investigator to the Minority JAMIE BENCE Law Clerk BILL GAERTNER Law Clerk CURTIS KOWALK Law Clerk KATIE MARTIN-BROWNE Law Clerk WELLESLEY BAUN Law Clerk LAUREN ROBERTS Law Clerk MICHAEL WOLF Law Clerk ARIELLE WORONOFF Law Clerk TAMIR HADDAD Intern SOFIA KNUTSSON Intern NOELIA ORTIZ Intern JASWANT SINGH Intern MARY D. ROBERTSON Chief Clerk 9/6/12 Permanent Subcommittee on Investigations 199 Russell Senate Office Building - Washington, D.C. 20510 Majority : 202/224-9505 - Minority : 202/224-3721 Web Address : http://www.hsgac.senate.gov/subcommittees/investigations Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 3 of 339 PagelD #: 1342 U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History TABLE OF CONTENTS I. EXECUTIVE SUMMARY 1 A. Findings 10 (1) Longstanding Severe AML Deficiencies 10 (2) Taking on High Risk Affiliates 10 (3) Circumventing OF AC Prohibitions 10 (4) Disregarding Terrorist Links 10 (5) Clearing Suspicious Bulk Travelers Cheques 10 (6) Offering Bearer Share Accounts 10 (7) Allowing AML Problems to Fester 11 B. Recommendations 11 (1) Screen High Risk Affiliates 11 (2) Respect OFAC Prohibitions 11 (3) Close Accounts for Banks with Terrorist Financing Links 11 (4) Revamp Travelers Cheque AML Controls 11 (5) Boost Information Sharing Among Affiliates 11 (6) Eliminate Bearer Share Accounts 11 (7) Increase HBUS' AML Resources 12 (8) Treat AML Deficiencies as a Matter of Safety and Soundness 12 (9) Act on Multiple AML Problems 12 (10) Strengthen AML Examinations 12 H. GENERAL BACKGROUND 13 A. Background on HSBC Group and HBUS 13 B. HBUS AML Program 19 (1) HBUS Compliance and AML Leadership 21 (2) HBUS AML Program 25 III. HBMX: PROVIDING U.S. ACCESS TO A HIGH RISK AFFILIATE 35 A. HSBC Mexico 36 B. Mexico 38 (1) U.S. Assessment of AML Risk in Mexico 39 (2) HSBC Assessment of Risk in Mexico 42 C. HBMX's History of Weak AML Safeguards 48 D. HBMX High Risk Clients 79 (1) High Risk Money Service Businesses 80 (a) Casa de Cambio Puebla 80 (b) Sigue Corporation 85 i Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 4 of 339 PagelD #: 1343 (2) Cayman Island U.S. Dollar Accounts 91 (3) Cashing U.S. Dollar Travelers Cheques 100 E. Bulk Cash Movements 105 (1) HBUS' Global Banknotes Business 105 (2) HBMX U.S. Dollar Sales to HBUS 107 (3) Remedial Action 110 F. Analysis Ill IV. HSBC AFFILIATES: CIRCUMVENTING OFAC PROHIBITIONS 113 A. Background on OFAC Prohibitions 115 B. Executing OFAC-Sensitive Transactions 119 (1) Transactions Involving Iran 119 (a) Overview 119 (b) Concealing Iranian Transactions 122 (c) Pressuring HBUS on Iran 129 (d) Continuing Pressure on HBUS to Process Iranian Transactions 133 (e) Reaching Agreement 144 (f) Processing the Iranian Transactions 151 (g) Establishing Group-wide Policy 156 (h) Shifting Iranian Transactions from HBUS to JPMorgan Chase and and Back Again 159 (i) Getting Out 163 (j) Looking Back 166 (2) Transactions Involving Other Countries 167 (a) 2005 and 2006 GCLs 167 (b) Transactions Involving Cuba 170 (c) Transactions Involving Sudan 172 (d) Transactions Involving Burma 174 (e) Transactions Involving North Korea 176 (f) Other Prohibited Transactions 176 (3) HBUS' OFAC Compliance Program 178 (4) Server Issues 183 C. Analysis 188 V. AL RAJHI BANK: DISREGARDING LINKS TO TERRORIST FINANCING .... 189 A. Al Raj hi Bank 190 B. Saudi Arabia and Terrorist Financing 191 C. Alleged Al Rajhi Links to Terrorism 194 D. HSBC Relationship with Al Rajhi Bank 203 E. Al Rajhi Trading Establishment 204 F. 2005: Decision to Sever Ties with Al Rajhi Bank 206 G. 2006: HBUS Banknotes Account Reinstated 210 H. 2007 to 2010: Additional Troubling Information 221 ii Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 5 of 339 PagelD #: 1344 I. Servicing Other Banks with Suspected Links to Terrorism 224 (1) Islami Bank Bangladesh Ltd 224 (2) Social Islami Bank Ltd 230 J. Analysis 238 VI. HOKURIKU BANK: CASHING BULK TRAVELERS CHECKS 240 A. HokurikuBank 241 B. Travelers Cheques 242 C. 2005 Concerns About Hokuriku Travelers Cheques 244 D. 2007 OCC Pouch Examination 245 E. 2008 OCC Inquiry into Hokuriku Travelers Cheques 248 F. Absence of Hokuriku Bank KYC Information 251 G. 2008 Decision to Stop Cashing Hokuriku Travelers Cheques 252 H. Hokuriku Bank's Continued Lack of Cooperation 254 I. 2010 OCC Discovery of Hokuriku Account Activity 257 J. Analysis 258 VII. HBUS PRIVATE BANK AMERICAS: OFFERING BEARER SHARE ACCOUNTS 260 A. High Risk Corporate Accounts 261 B. Bearer Share Activity at HBUS 263 C. Two Examples of Bearer Share Accounts 277 D. Analysis 281 VIII. OCC: EXERCISING INEFFECTIVE AML OVERSIGHT 282 A. Background 284 (1) Key Anti-Money Laundering Laws 284 (2) AML Oversight In General 286 (3) OCC AML Oversight in General 292 B. OCC Oversight of HBUS 299 (1) Chronology of OCC AML Oversight of HBUS 299 (2) Six Years of AML Deficiencies 315 C. OCC Systemic Failures 318 (1) Treating AML Deficiencies As A Consumer Compliance Issue 318 (2) Restricting Citations of AML Program Violations 321 (3) Using Narrowly Focused Exams 325 (4) Failing to Use Enforcement Actions 328 (5) Issuing Weak Supervisory Letters 329 D. Analysis 333 # # # iii Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 6 of 339 PagelD #: 1345 U.S. VULNERABILITIES TO MONEY LAUNDERING, DRUGS, AND TERRORIST FINANCING: HSBC CASE HISTORY This Report examines the anti-money laundering (AML) and terrorist financing vulnerabilities created when a global bank uses its U.S. affiliate to provide U.S. dollars, U.S. dollar services, and access to the U.S. financial system to high risk affiliates, high risk correspondent banks, and high risk clients. This Report also offers recommendations to strengthen correspondent AML controls to combat money laundering, drug trafficking, and terrorist financing. I. EXECUTIVE SUMMARY Over the last decade, the U.S. Senate Permanent Subcommittee on Investigations has worked to strengthen U.S. AML efforts by investigating how money launderers, terrorists, organized crime, corrupt officials, tax evaders, and other wrongdoers have utilized U.S. financial institutions to conceal, transfer, and spend suspect funds. 1 In 2001, the Subcommittee focused, in particular, on how U.S. banks, through the correspondent services they provide to foreign financial institutions, had become conduits for illegal proceeds associated with organized crime, drug trafficking, and financial fraud. 2 Correspondent banking occurs when one financial institution provides services to another financial institution to move funds, exchange currencies, cash monetary instruments, or carry out other financial transactions. The Subcommittee's 2001 investigation showed not only how some poorly managed or corrupt foreign banks used U.S. bank accounts to aid and abet, commit, or allow clients to commit wrongdoing, but also how U.S. financial institutions could protect themselves and the U.S. financial system from misuse. In response to that investigation and the money laundering vulnerabilities exposed by the 9/11 terrorist attack, Congress enacted stronger AML laws as part of the Patriot Act of 2002, including stronger provisions to combat the misuse of correspondent services. 3 Federal bank regulators followed with stronger regulations 4 and examination requirements 5 to guard against See, e.g., U.S. Senate Permanent Subcommittee on Investigations, "Keeping Foreign Corruption out of the United States," S.Hrg. 1 1 1-540 (Feb. 4, 2010); "Tax Haven Banks and U.S. Tax Compliance," S.Hrg. 1 10-614 (July 17 and 25, 2008); "Tax Haven Abuses: The Enablers, The Tools and Secrecy," S.Hrg. 109-797 (Aug. 1, 2006); "Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act," S.Hrg. 108-633 (July 15, 2004); "Role of U.S. Correspondent Banking in International Money Laundering," S.Hrg. 107-84 (March 1, 2 and 6, 2001); and "Private Banking and Money Laundering: A Case Study of Opportunities and Vulnerabilities," S.Hrg. 106-428 (Nov. 9 and 10, 1999). See also U.S. Senate Committee on Homeland Security and Governmental Affairs, "State Business Incorporation - 2009," S.Hrg. 111-953 (June 18 and Nov. 5,2009). 2 "Role of U.S. Correspondent Banking in International Money Laundering," U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 107-84 (March 1, 2 and 6, 2001)(hereinafter "2001 Subcommittee Hearing on Correspondent Banking"), at 1. 3 See, e.g., Sections 312, 313, and 319(b) of the USA Patriot Act (requiring due diligence to be conducted when opening accounts for foreign banks, with enhanced due diligence for offshore banks and banks in high risk jurisdictions; prohibiting the opening of correspondent accounts for shell banks; and strengthening the ability of U.S. regulators to obtain correspondent account records). 4 See, e.g., 31 CFR §§103.175,103.176, 103.177, 103.185. 5 See, e.g., 4/29/2010 "Bank Secrecy Act/ Anti-Money Laundering Examination Manual," issued by the Federal Financial Institutions Examination Council, "Foreign Correspondent Account Recordkeeping and Due Diligence," at Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 7 of 339 PagelD #: 1346 2 money laundering through correspondent accounts. In response, over the next ten years, U.S. banks substantially strengthened their correspondent AML controls. Before the 2002 Patriot Act, for example, most U.S. banks opened correspondent accounts for any foreign bank with a banking license; now, most U.S. banks evaluate the riskiness of each foreign bank's owners, business lines, products, clients, and AML controls before agreeing to open an account. They also routinely monitor account activity and wire transfers for suspicious activity, with enhanced monitoring of high risk correspondents. In addition, before the 2002 Patriot Act, some U.S. banks readily opened accounts for foreign shell banks, meaning banks without any physical presence in any jurisdiction; today, in accordance with the Patriot Act's ban on shell bank accounts, all U.S. banks take measures to ensure they don't provide services to such banks, the ban on shell bank accounts has become an international AML standard, 6 and the thousands of stand-alone shell banks licensed by the Bahamas, Cayman Islands, Nauru, and other jurisdictions have virtually disappeared. At the same time, the money laundering risks associated with correspondent banking have not been eliminated. Correspondent accounts continue to provide a gateway into the U.S. financial system, and wrongdoers continue to abuse that entryway. This investigation takes a fresh look at the U.S. vulnerabilities to money laundering and terrorist financing associated with correspondent banking, focusing in particular on the operations of global banks with U.S. affiliates that enable foreign financial institutions to gain access to the U.S. financial system. HSBC Case Study. To examine the current money laundering and terrorist financing threats associated with correspondent banking, the Subcommittee selected HSBC as a case study. HSBC is one of the largest financial institutions in the world, with over $2.5 trillion in assets, 89 million customers, 300,000 employees, and 201 1 profits of nearly $22 billion. HSBC, whose initials originally stood for Hong Kong Shanghai Banking Corporation, now has operations in over 80 countries, with hundreds of affiliates spanning the globe. Its parent corporation, HSBC Holdings pic, called "HSBC Group," is headquartered in London, and its Chief Executive Officer is located in Hong Kong. Its key U.S. affiliate is HSBC Bank USA NA. (HBUS). HBUS operates more than 470 bank branches throughout the United States, manages assets totaling about $200 billion, and serves around 3.8 million customers. It holds a national bank charter, and its primary regulator is the U.S. Office of the Comptroller of the Currency (OCC), which is part of the U.S. Treasury Department. HBUS is headquartered in McLean, Virginia, but has its principal office in New York City. HSBC acquired its U.S. presence by purchasing several U.S. financial institutions, including Marine Midland Bank and Republic National Bank of New York. A senior HSBC executive told the Subcommittee that HSBC acquired its U.S. affiliate, not just to compete with other U.S. banks for U.S. clients, but primarily to provide a U.S. platform to its non-U. S. clients and to use its U.S. platform as a selling point to attract still more non-U. S. clients. HSBC operates in many jurisdictions with weak AML controls, high risk 117-129, 183-187, http://www.ffiec.gov^sa_aml_infobase/documents/BSA_AML_Man_2010.pdf. Prior versions of this Manual were issued in 2005 and 2007. 6 See "International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation: The FATF Recommendations," issued by the Financial Action Task Force (2/2012), FATF Recommendation 13. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 8 of 339 PagelD #: 1347 3 clients, and high risk financial activities including Asia, Middle East, and Africa. Over the past ten years, HSBC has also acquired affiliates throughout Latin America. In many of these countries, the HSBC affiliate provides correspondent accounts to foreign financial institutions that, among other services, are interested in acquiring access to U.S. dollar wire transfers, foreign exchange, and other services. As a consequence, HSBC's U.S. affiliate, HBUS, is required to interact with other HSBC affiliates and foreign financial institutions that face substantial AML challenges, often operate under weaker AML requirements, and may not be as familiar with, or respectful of, the tighter AML controls in the United States. HBUS' correspondent services, thus, provide policymakers with a window into the vast array of money laundering and terrorist financing risks confronting the U.S. affiliates of global banks. The Subcommittee also examined HSBC because of its weak AML program. In September 2010, the OCC issued a lengthy Supervisory Letter citing HBUS for violating Federal AML laws, including by maintaining an inadequate AML program. In October 2010, the OCC issued a Cease and Desist Order requiring HSBC to strengthen multiple aspects of its AML program. 7 The identified problems included a once massive backlog of over 17,000 alerts identifying possible suspicious activity that had yet to be reviewed; ineffective methods for identifying suspicious activity; a failure to file timely Suspicious Activity Reports with U.S. law enforcement; a failure to conduct any due diligence to assess the risks of HSBC affiliates before opening correspondent accounts for them; a 3 -year failure by HBUS, from mid-2006 to mid- 2009, to conduct any AML monitoring of $15 billion in bulk cash transactions with those same HSBC affiliates, despite the risks associated with large cash transactions; poor procedures for assigning country and client risk ratings; a failure to monitor $60 trillion in annual wire transfer activity by customers domiciled in countries rated by HBUS as lower risk; inadequate and unqualified AML staffing; inadequate AML resources; and AML leadership problems. Since many of these criticisms targeted severe, widespread, and longstanding AML deficiencies, they also raised questions about how the problems had been allowed to accumulate and why the OCC had not compelled corrective action earlier. During the course of its investigation into HSBC's AML deficiencies, the Subcommittee issued multiple subpoenas and collected and reviewed over 1 .4 million documents, including bank records, correspondence, emails, and legal pleadings. The Subcommittee staff also conducted over 75 interviews with officials at HSBC Group, HBUS, and other HSBC affiliates, as well as with U.S. banking regulators. In addition, the Subcommittee received numerous briefings from HSBC legal counsel, initiated inquiries with foreign banks that had HSBC accounts, and consulted with experts on AML and terrorist financing issues. HSBC was fully cooperative with the inquiry, producing documentation and witnesses from around the world, including documents for which it could have claimed privilege. As a result of its investigation, the Subcommittee has focused on five issues illustrating key AML and terrorist financing problems that continue to impact correspondent banking in the United States. They include opening U.S. correspondent accounts for high risk affiliates without conducting due diligence; facilitating transactions that hinder U.S. efforts to stop terrorists, drug 7 On the same day, in coordination with the OCC, the Federal Reserve issued a Cease and Desist order to HBUS' holding company, HSBC North America Holdings, Inc. (HNAH), citing HNAH for an inadequate AML program and requiring it to revamp and strengthen both its program and that of HBUS. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 9 of 339 PagelD #: 1348 4 traffickers, rogue jurisdictions, and other from using the U.S. financial system; providing U.S. correspondent services to banks with links to terrorism; clearing bulk U.S. dollar travelers cheques despite signs of suspicious activity; and offering high risk bearer share corporate accounts. Avoiding the money laundering risks involved in these activities requires an effective AML program, with written standards, knowledgeable and adequate staff, the infrastructure needed to monitor account and wire transfer activity for suspicious transactions, effective AML training, and a compliance culture that values obtaining accurate client information. In addition to focusing on these five issues at HBUS, the Subcommittee investigation examined the regulatory failures that allowed these and other AML problems to fester for years. Servicing A High Risk Affiliate. In 2001, the Subcommittee's investigation debunked the notion that U.S. banks should open a correspondent account for any foreign bank with a banking license, establishing instead the need to use due diligence to evaluate the money laundering and terrorist financing risks posed by a specific foreign financial institution before opening an account. Today, some U.S. affiliates of global banks engage in an equally ill-advised practice, opening correspondent accounts for any affiliate owned by the parent holding corporation, with no analysis of the AML or terrorist financing risks. Until recently, HSBC Group policy instructed its affiliates to assume that all HSBC affiliates met the Group's AML standards and to open correspondent accounts for those affiliates without additional due diligence. For years, HBUS followed that policy, opening U.S. correspondent accounts for HSBC affiliates without conducting any AML due diligence. Those affiliates have since become major clients of the bank. In 2009, for example, HBUS determined that "HSBC Group affiliates clear[ed] virtually all USD [U.S. dollar] payments through accounts held at HBUS, representing 63% of all USD payments processed by HBUS." 8 HBUS failed to conduct due diligence on HSBC affiliates despite a U.S. law that has required all U.S. banks, since 2002, to conduct these due diligence reviews before opening a U.S. correspondent account for any foreign financial institution, with no exception made for foreign affiliates. One HSBC affiliate that illustrates the AML problems is HSBC Mexico, known as HBMX. HBUS should have, but did not, treat HBMX as a high risk correspondent client subject to enhanced due diligence and monitoring. HBMX operated in Mexico, a country under siege from drug crime, violence and money laundering; it had high risk clients, such as Mexican casas de cambios and U.S. money service businesses; and it offered high risk products, such as U.S. dollar accounts in the Cayman Islands. In addition, from 2007 through 2008, HBMX was the single largest exporter of U.S. dollars to HBUS, shipping $7 billion in cash to HBUS over two years, outstripping larger Mexican banks and other HSBC affiliates. Mexican and U.S. authorities expressed repeated concern that HBMX's bulk cash shipments could reach that volume only if they included illegal drug proceeds. The concern was that drug traffickers unable to deposit large amounts of cash in U.S. banks due to AML controls were transporting U.S. dollars to Mexico, arranging for bulk deposits there, and then using Mexican financial institutions to insert the cash back into the U.S. financial system. See 9/9/2009 chart entitled, "HSBC Profile," included in "HSBC OFAC Compliance Program," a presentation prepared by HSBC and provided to the OCC, at HSBC OCC 8874197. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 10 of 339 PagelD #: 1349 5 In addition to its high risk location, clients, and activities, HMBX had a history of severe AML deficiencies. Its AML problems included a widespread lack of Know Your Customer (KYC) information in client files; a dysfunctional monitoring system; bankers who resisted closing accounts despite evidence of suspicious activity; high profile clients involved in drug trafficking; millions of dollars in suspicious bulk travelers cheque transactions; inadequate staffing and resources; and a huge backlog of accounts marked for closure due to suspicious activity, but whose closures were delayed. For eight years, from 2002 to 2010, HSBC Group oversaw efforts to correct HBMX's AML deficiencies, while those efforts fell short. At the same time, HSBC Group watched HBMX utilize its U.S. correspondent account, without alerting HBUS to the AML risks it was incurring. HBUS compounded the AML risks it incurred from HBMX through its own AML deficiencies, which included failing to investigate or evaluate HBMX's AML risks. HBUS also failed, from mid-2006 to mid-2009, to conduct any AML monitoring of its U.S. dollar transactions with HSBC affiliates, including HBMX, despite the obvious well-known risks attendant with large cash transactions. In addition, because HBUS deemed HBMX to be located in a low risk country, HBUS failed until 2009, to monitor HBMX's wire transfer or account activity. HBMX illustrates the money laundering and drug trafficking risks that result when the U.S. affiliate of a global bank serves as the U.S. gateway for a high risk affiliate allowed to operate with no initial due diligence or ongoing monitoring. Circumventing OF AC Prohibitions. The United States has devoted significant resources to stopping some of the most dangerous persons and jurisdictions threatening the world today from utilizing the U.S. financial system, including terrorists, persons involved with weapons of mass destruction, drug traffickers, and persons associated with rogue jurisdictions such as Iran, North Korea, and Sudan. To implement the law, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) has developed a list of prohibited persons and countries which banks use to create an "OFAC filter" to identify and halt potentially prohibited transactions. Transactions stopped by this filter typically undergo an individualized review to see if the transaction can proceed or the funds must be blocked. Because the OFAC filter can end up delaying or blocking transactions that are permitted under U.S. law or by other jurisdictions, some non-U. S. financial institutions have used tactics to circumvent it. Common tactics include stripping information from wire transfer documentation to conceal the participation of a prohibited person or country, or characterizing a transaction as a transfer between banks in approved jurisdictions, while omitting underlying payment details that would disclose participation of a prohibited originator or beneficiary. In the case of Iran, some foreign banks also abused what were known as "U-turn" transactions, which were allowable transactions under Treasury regulations prior to November 2008. In recent years, the United States has imposed steep penalties on banks that violated the OFAC prohibitions. At HBUS, documents provided to the Subcommittee indicate that, for years, some HSBC affiliates took action to circumvent the OFAC filter when sending OFAC sensitive transactions through their U.S. dollar correspondent accounts at HBUS. From at least 2001 to 2007, two HSBC affiliates, HSBC Europe (HBEU) and HSBC Middle East (HBME), repeatedly sent U- turn transactions through HBUS without disclosing links to Iran, even though they knew HBUS Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 11 of 339 PagelD #: 1350 6 required full transparency to process U-turns. To avoid triggering the OFAC filter and an individualized review by HBUS, HBEU systematically altered transaction information to strip out any reference to Iran and characterized the transfers as between banks in approved jurisdictions. The affiliates' use of these practices, which even some within the bank viewed as deceptive, was repeatedly brought to the attention of HSBC Group Compliance, by HBUS compliance personnel and by HBEU personnel who objected to participating in the document alteration and twice announced deadlines to end the activity. Despite this information, HSBC Group Compliance did not take decisive action to stop the conduct or inform HBUS about the extent of the activity. At the same time, while some at HBUS claimed not to have known they were processing undisclosed Iranian transactions from HSBC affiliates, internal documents show key senior HBUS officials were informed as early as 2001. In addition, HBUS' OFAC filter repeatedly stopped Iranian transactions that should have been disclosed to HBUS by HSBC affiliates, but were not. Despite evidence of what was taking place, HBUS failed to get a full accounting of what its affiliates were doing or ensure all Iranian transactions sent by HSBC affiliates were stopped by the OFAC filter and reviewed to ensure they were OFAC compliant. In addition, documents show that, from 2002 to 2007, some HSBC affiliates sent potentially prohibited transactions through HBUS involving Burma, Cuba, North Korea, Sudan, and other prohibited countries or persons. Other documents indicate that some HSBC affiliates may have sent non-U. S. dollar messaging traffic through U.S. servers in which the OFAC filter was not turned on or was restricted. An outside auditor hired by HBUS has so far identified, from 2001 to 2007, more than 28,000 undisclosed, OFAC sensitive transactions that were sent through HBUS involving $19.7 billion. Of those 28,000 transactions, nearly 25,000 involved Iran, while 3,000 involved other prohibited countries or persons. The review has characterized nearly 2,600 of those transactions, including 79 involving Iran, and with total assets of more than $367 million, as "Transactions of Interest" requiring additional analysis to determine whether violations of U.S. law occurred. While the aim in many of those cases may have been to avoid the delays associated with the OFAC filter and individualized reviews, rather than to facilitate prohibited transactions, actions taken by HSBC affiliates to circumvent OFAC safeguards may have facilitated transactions on behalf of terrorists, drug traffickers, or other wrongdoers. While HBUS insisted, when asked, that HSBC affiliates provide fully transparent transaction information, when it obtained evidence that some affiliates were acting to circumvent the OFAC filter, HBUS failed to take decisive action to confront those affiliates and put an end to the conduct. HBUS' experience demonstrates the strong measures that the U.S. affiliate of a global bank must take to prevent affiliates from circumventing OFAC prohibitions. Disregarding Links to Terrorism. For decades, HSBC has been one of the most active global banks in the Middle East, Asia, and Africa, despite being aware of the terrorist financing risks in those regions. In particular, HSBC has been active in Saudi Arabia, conducting substantial banking activities through affiliates as well as doing business with Saudi Arabia's largest private financial institution, Al Rajhi Bank. After the 9/11 terrorist attack in 2001, evidence began to emerge that Al Rajhi Bank and some of its owners had links to financing organizations associated with terrorism, including evidence that the bank's key founder was an early financial benefactor of al Qaeda. In 2005, HSBC announced internally that its affiliates should sever ties with Al Rajhi Bank, Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 12 of 339 PagelD #: 1351 7 but then reversed itself four months later, leaving the decision up to each affiliate. HSBC Middle East, among other HSBC affiliates, continued to do business with the bank. Due to terrorist financing concerns, HBUS closed the correspondent banking and banknotes accounts it had provided to Al Rajhi Bank. For nearly two years, HBUS Compliance personnel resisted pressure from HSBC personnel in the Middle East and United States to resume business ties with Al Rajhi Bank. In December 2006, however, after Al Rajhi Bank threatened to pull all of its business from HSBC unless it regained access to HBUS' U.S. banknotes program, HBUS agreed to resume supplying Al Rajhi Bank with shipments of U.S. dollars. Despite ongoing troubling information, HBUS provided nearly $1 billion in U.S. dollars to Al Rajhi Bank until 2010, when HSBC decided, on a global basis, to exit the U.S. banknotes business. HBUS also supplied U.S. dollars to two other banks, Island Bank Bangladesh Ltd. and Social Island Bank, despite evidence of links to terrorist financing. Each of these specific cases shows how a global bank can pressure its U.S. affiliate to provide banks in countries at high risk of terrorist financing with access to U.S. dollars and the U.S. financial system. Clearing Suspicious Bulk Travelers Cheques. Another AML issue involves HBUS' clearing more than $290 million in bulk U.S. dollar travelers checks in less than four years for a Japanese regional bank, Hokuriku Bank, despite evidence of suspicious activity. From at least 2005 to 2008, HBUS cleared bulk travelers cheques for Hokuriku Bank on a daily basis, at times clearing $500,000 or more in U.S. dollars per day. The cheques were in denominations of $500 or $1,000, submitted in large blocks of sequentially numbered cheques, and signed and countersigned with the same illegible signature. An OCC examination which determined that HBUS was clearing travelers cheques with inadequate AML controls, discovered the stacks of Hokuriku travelers cheques being processed on a daily basis, and directed HBUS to investigate. When HBUS sought more information, Hokuriku Bank at first delayed responding, then provided minimal information, and finally declined to investigate further, claiming to be constrained by bank secrecy laws from disclosing client-specific information. HBUS eventually learned that the travelers cheques were purchased by Russians from a bank in Russia, a country at high risk of money laundering. HBUS also learned that the Japanese bank had little KYC information or understanding why up to $500,000 or more in bulk U.S. dollar travelers cheques purchased in Russia were being deposited on a daily basis into one of 30 different Japanese accounts of persons and corporations supposedly in the used car business. In October 2008, under pressure from the OCC, HBUS stopped processing the travelers cheques, but continued the correspondent relationship, despite the Japanese bank's poor AML controls. Two years later, in 2010, an OCC examination uncovered the ongoing relationship, between HSBC and Hokuriku, which the OCC thought had ended. In 2012, after the Subcommittee inquired about the account, HBUS closed it. Since travelers cheques have been misused by terrorists, drug traffickers, and other criminals, the HBUS experience shows how a U.S. affiliate with ineffective AML controls can end up clearing suspicious bulk travelers cheques and facilitating the movement of hundreds of millions of U.S. dollars across international lines to unknown recipients. Offering Bearer Share Accounts. Over the course of a decade, HBUS opened over 2,000 accounts in the name of bearer share corporations, a notorious type of corporation that Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 13 of 339 PagelD #: 1352 8 invites secrecy and wrongdoing by assigning ownership to whomever has physical possession of the shares. At its peak, HBUS' Miami office had over 1,670 bearer share accounts; the New York office had over 850; and the Los Angeles office had over 30. The Miami bearer share accounts alone held assets totaling an estimated $2.6 billion, and generated annual bank revenues of $26 million. Multiple internal audits and regulatory examinations criticized the accounts as high risk and advocated that HBUS either take physical custody of the shares or require the corporations to register the shares in the names of the shareholders, but HBUS bankers initially resisted tightening AML controls, and regulators took no enforcement action. Two examples of the accounts illustrate the risks they posed. In the first, Miami Beach hotel developers, Mauricio Cohen Assor and Leon Cohen Levy, father and son, used bearer share accounts they opened for Blue Ocean Finance Ltd. and Whitebury Shipping Time-Sharing Ltd. to help hide $150 million in assets and $49 million in income. In 2010, both were convicted of criminal tax fraud and filing false tax returns, sentenced to ten years in prison, and ordered to pay back taxes, interest, and penalties totaling more than $17 million. A second example involves a wealthy and powerful Peruvian family which pressed HBUS to grant a waiver from its AML requirements that bearer share corporations either register their shares or place those shares in bank custody. Bank documents showed how HBUS bankers pressed Compliance personnel to grant the waiver to please a wealthy client. These accounts demonstrate the AML risks associated with bearer share accounts, whose owners seek to hide their identities. Today, following an initiative that concluded in 201 1, HBUS has reduced its bearer share accounts to 26, most of which are frozen, while at the same time maintaining a policy that allows the bank to open new bearer share accounts in the future. Regulatory Failures. HBUS' severe AML deficiencies did not happen overnight; they accumulated over time, even though its primary regulator, the OCC, conducted regular AML examinations. Part of the reason HBUS' AML problems were not cured is attributable to certain peculiar and ineffective aspects of the OCC's AML oversight effort. First, unlike other U.S. bank regulators, the OCC does not treat AML deficiencies as a matter of bank safety and soundness or a management problem. Instead it treats AML deficiencies as a consumer compliance matter, even though AML laws and consumer protection laws have virtually nothing in common. One consequence of this approach is that the OCC considers AML problems when assigning a bank's consumer compliance rating, but not when assigning the bank's management rating or its overall composite rating. As a result, AML deficiencies do not routinely lower the ratings that national banks receive as part of their safety and soundness evaluations, and so do not increase the deposit insurance that banks pay for incurring heightened risk, contrary to how AML problems are handled at other Federal banking agencies. At HBUS, after citing the bank for severe AML deficiencies, the OCC lowered its consumer compliance rating but not its management rating. A second problem is that the OCC has adopted a practice of foregoing the citation of a statutory or regulatory violation in its Supervisory Letters and annual Reports of Examination when a bank fails to comply with one of the four mandatory components of an AML program. The four minimum statutory requirements of an AML program are AML internal controls, an AML compliance officer, AML training, and independent testing of the effectiveness of its AML Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 14 of 339 PagelD #: 1353 9 program. By consistently treating a failure to meet one or even several of these statutory requirements as a "Matter Requiring Attention" instead of a legal violation, the OCC diminishes the importance of meeting each requirement, sends a more muted message about the need for corrective action, and makes enforcement actions more difficult to pursue if an AML deficiency persists. In contrast, citing a violation of law when one critical component of a bank's AML program is inadequate sends a strong message to bank management that its AML program is deficient, does not meet minimum statutory requirements, and requires remediation to ensure compliance with the law. At HBUS, the OCC identified 83 Matters Requiring Attention over five years, without once citing a legal violation of Federal AML law. It was only when the OCC found HBUS' entire AML program to be deficient that the OCC finally cited the bank for a legal violation. Additional problems illustrated by the HBUS case history include the OCC's practice of conducting narrowly focused AML examinations of specific banking units without also assessing HBUS' overall AML program; the OCC's reluctance, despite mounting AML deficiencies, to make timely use of formal and informal enforcement actions to compel improvements in HBUS' AML program; and the practice by some OCC examiners to issue Supervisory Letters that sometimes muted AML examination criticisms or weakened recommendations for AML reforms at HBUS. While the OCC insists that its AML approach has merit, the HSBC case history, like the Riggs Bank case history examined by this Subcommittee eight years ago, 9 provides evidence that the current OCC system has tolerated severe AML deficiencies for years, permitted national banks to delay or avoid correcting identified problems, and allowed smaller AML issues to accumulate into a massive problem before OCC enforcement action was taken. An experienced OCC AML examiner told the Subcommittee: "I thought I saw it all with Riggs but HSBC was the worst situation I'd ever seen," yet during the six-year period from 2004 to 2010, OCC officials did not take any formal or informal enforcement action to compel HBUS to strengthen its AML program, essentially allowing its AML problems to fester. In 2009, after learning of two law enforcement investigations involving AML issues at the bank, the OCC suddenly expanded and intensified an ongoing AML examination and allowed it to consider a wide range of AML issues. The OCC examination culminated in the issuance, in September 2010, of a blistering supervisory letter listing numerous, serious AML problems at the bank. In October 2010, the OCC also issued a Cease and Desist Order requiring HBUS to revamp its AML controls. In response, HBUS has announced a number of key organizational and policy initiatives to improve its AML program in the United States and globally. While those initiatives are promising, HBUS announced similarly promising AML reforms in 2003, when confronted with an AML enforcement action by the Federal Reserve Bank of New York and New York State Banking Department. Even before the OCC lifted that order in 2006, HBUS' AML program deteriorated. Both HBUS and the OCC will have to undertake a sustained effort to ensure the newest round of changes produce a better AML outcome. 9 See "Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act," U.S. Senate Permanent Subcommittee on Investigations, S.Hrg. 108-633 (July 15, 2004). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 15 of 339 PagelD #: 1354 10 HSBC is the quintessential global bank, operating hundreds of affiliates in 80 countries, with its U.S. affiliate acting as the gateway into the U.S. financial system for the entire network. The OCC allowed AML problems at HBUS to build up until they represented major AML vulnerabilities for the United States. Going forward, HBUS needs far stronger controls to ensure it doesn't leave AML risks to the U.S. financial system unattended; the OCC needs a much better approach to resolve AML problems in a more effective and timely manner. A. Findings This Report makes the following findings of fact. (1) Longstanding Severe AML Deficiencies. HBUS operated its correspondent accounts for foreign financial institutions with longstanding, severe AML deficiencies, including a dysfunctional AML monitoring system for account and wire transfer activity, an unacceptable backlog of 17,000 unreviewed alerts, insufficient staffing, inappropriate country and client risk assessments, and late or missing Suspicious Activity Reports, exposing the United States to money laundering, drug trafficking, and terrorist financing risks. (2) Taking on High Risk Affiliates. HBUS failed to assess the AML risks associated with HSBC affiliates before opening correspondent accounts for them, failed to identify high risk affiliates, and failed for years to treat HBMX as a high risk accountholder. (3) Circumventing OFAC Prohibitions. For years in connection with Iranian U-turn transactions, HSBC allowed two non-U. S. affiliates to engage in conduct to avoid triggering the OFAC filter and individualized transaction reviews. While HBUS insisted, when asked, that HSBC affiliates provide fully transparent transaction information, when it obtained evidence that some affiliates were acting to circumvent the OFAC filter, HBUS failed to take decisive action to confront those affiliates and put an end to conduct which even some within the bank viewed as deceptive. (4) Disregarding Terrorist Links. HBUS provided U.S. correspondent accounts to some foreign banks despite evidence of links to terrorist financing. (5) Clearing Suspicious Bulk Travelers Cheques. In less than four years, HBUS cleared over $290 million in sequentially numbered, illegibly signed, bulk U.S. dollar travelers cheques for Hokuriku Bank, which could not explain why its clients were regularly depositing up to $500,000 or more per day in U.S. dollar travelers cheques obtained in Russia into Japanese accounts, supposedly for selling used cars; even after learning of Hokuriku' s poor AML controls, HBUS continued to do business with the bank. (6) Offering Bearer Share Accounts. Over the course of a decade, HBUS opened over 2,000 high risk bearer share corporate accounts with inadequate AML controls. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 16 of 339 PagelD #: 1355 11 (7) Allowing AML Problems to Fester. The OCC allowed HBUS' AML deficiencies to fester for years, in part due to treating HBUS' AML problems as consumer compliance matters rather than safety and soundness problems, failing to make timely use of formal and informal enforcement actions to compel AML reforms at the bank, and focusing on AML issues in specific HBUS banking units without also viewing them on an institution-wide basis. B. Recommendations This Report makes the following recommendations. (1) Screen High Risk Affiliates. HBUS should reevaluate its correspondent relationships with HSBC affiliates, including by reviewing affiliate AML and compliance audit findings, identifying high risk affiliates, designating affiliate accounts requiring enhanced monitoring, and closing overly risky accounts. HBUS should conduct a special review of the HBMX account to determine whether it should be closed. (2) Respect OFAC Prohibitions. HSBC Group and HBUS should take concerted action to stop non-U. S. HSBC affiliates from circumventing the OFAC filter that screens transactions for terrorists, drug traffickers, rogue jurisdictions, and other wrongdoers, including by developing audit tests to detect undisclosed OFAC sensitive transactions by HSBC affiliates. (3) Close Accounts for Banks with Terrorist Financing Links. HBUS should terminate correspondent relationships with banks whose owners have links to, or present high risks of involvement with, terrorist financing. (4) Revamp Travelers Cheque AML Controls. HBUS should restrict its acceptance of large blocks of sequentially numbered U.S. dollar travelers cheques from HSBC affiliates and foreign financial institutions; identify affiliates and foreign financial institutions engaged in suspicious travelers cheque activity; and stop accepting travelers cheques from affiliates and foreign banks that sell or cash U.S. dollar travelers cheques with little or no KYC information. (5) Boost Information Sharing Among Affiliates. HSBC should require AML personnel to routinely share information among affiliates to strengthen AML coordination, reduce AML risks, and combat wrongdoing. (6) Eliminate Bearer Share Accounts. HBUS should close its remaining 26 bearer share corporate accounts, eliminate this type of account, and instruct financial institutions using HBUS correspondent accounts not to execute transactions involving bearer share corporations. U.S. financial regulators should prohibit U.S. banks from opening or servicing bearer share accounts. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 17 of 339 PagelD #: 1356 12 (7) Increase HBUS' AML Resources. HBUS should ensure a full time professional serves as its AML director, and dedicate additional resources to hire qualified AML staff, implement an effective AML monitoring system for account and wire transfer activity, and ensure alerts, including OFAC alerts, are reviewed and Suspicious Activity Reports are filed on a timely basis. (8) Treat AML Deficiencies as a Matter of Safety and Soundness. The OCC should align its practice with that of other Federal bank regulators by treating AML deficiencies as a safety and soundness matter, rather than a consumer compliance matter, and condition management CAMELS ratings in part upon effective management of a bank's AML program. (9) Act on Multiple AML Problems. To ensure AML problems are corrected in a timely fashion, the OCC should establish a policy directing that the Supervision Division coordinate with the Enforcement and Legal Divisions to conduct an institution-wide examination of a bank's AML program and consider use of formal or informal enforcement actions, whenever a certain number of Matters Requiring Attention or legal violations identifying recurring or mounting AML problems are identified through examinations. (10) Strengthen AML Examinations. The OCC should strengthen its AML examinations by citing AML violations, rather than just Matters Requiring Attention, when a bank fails to meet any one of the statutory minimum requirements for an AML program; and by requiring AML examinations to focus on both specific business units and a bank's AML program as a whole. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 18 of 339 PagelD #: 1357 13 II. GENERAL BACKGROUND This section provides a general overview of HSBC Group, HSBC Bank USA (HBUS), and the HBUS compliance and anti-money laundering (AML) program. A. Background on HSBC Group and HBUS HSBC Group is one of the largest financial institutions in the world, with over $2.5 trillion in assets, 89 million customers, and 201 1 profits of nearly $22 billion. 10 Its parent corporation, HSBC Holdings pic, often referred to by the bank as "HSBC Group," is headquartered in London. Despite its London headquarters, the principal office of the Group Chief Executive is located in Hong Kong. 11 Altogether, HSBC has about 300,000 employees and 7,200 offices in over 80 countries, including North America, Europe, Asia, Latin America, the Middle East, and Africa. 12 United States Operations. Among other entities, the Group owns HSBC Overseas Holdings (UK) Ltd. (HSBC Overseas Holdings), which oversees its operations in the United States and Canada. HSBC Overseas Holdings owns, in turn, HSBC North America Holdings Inc. (HNAH, pronounced "Hannah"), one of the ten largest bank holding companies in the United States. HNAH has assets of about $345 billion, is headquartered in New York City, and 1 3 is overseen by the Federal Reserve. Through various subsidiaries, HNAH owns three key HSBC financial institutions in the United States: HSBC Bank USA NA. (HBUS); HSBC Securities (USA) Inc. (HSBC Securities); and HSBC Finance Corporation. HBUS operates more than 470 bank branches throughout the United States, manages assets totaling about $210 billion, and serves around 4 million customers. 14 It holds a national bank charter and its primary regulator is the Office of the Comptroller of the Currency (OCC), which is part of the U.S. Treasury Department. Because it holds insured deposits, its secondary regulator is the Federal Deposit Insurance Corporation (FDIC). HBUS is the principal subsidiary of HSBC USA Inc. (HUSI), a bank holding company which is a wholly-owned subsidiary of HNAH. 15 HBUS is headquartered in McLean, Virginia, and has its principal office in New York City. 16 1U See "HSBC Holdings pic 2011 Results-Highlights," (2/12/12), at 1-2, http://www.hsbc.com/l/PA_esf-ca-app- content/content/assets/investor_relations/hsbc201 larn.pdf; "HSBC Holdings pic Annual Report and Accounts 201 1," at 1, http://www.hsbc.eom/l/PA_esf-ca-app-content/content/assets/investor_relations/hsbc201 lara0.pdf (hereinafter "HSBC Group 201 1 Annual Report"). "See "HSBC Announces New Leadership Team," (9/24/10), media release prepared by HSBC, http://www.hsbc.eom/l/2/newsroom/news/2010/hsbc-announces-new-leadership. 12 HSBC Group 201 1 Annual Report at 1; "HSBC Announces New Leadership Team," (9/24/10), media release prepared by HSBC, http://www.hsbc.eom/l/2/newsroom/news/2010/hsbc-announces-new-leadership. 13 See "HSBC North America Holdings Inc. Fact Sheet," at 1, http://www.us.hsbc.eom/l/PA_l_083Q9FJ08A002FBP5S00000000/content/usshared/Inside%20HSBC/About%20 HSBC/Corporate%20Information/Corporate%20Facts/hnah_factsheet_09 1 1 .pdf. 14 "HSBC Bank USA, National Association Fact Sheet," at 1, http://www.us.hsbc.eom/l/PA_l_083Q9FJ08A002FBP5S00000000/content/usshared/Inside%20HSBC/About%20 HSBC/Corporate%20Information/Corporate%20Facts/hbus_factsheet_091 1. pdf (hereinafter "HBUS Fact Sheet"). 15 Id. 16 Id. at 2. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 19 of 339 PagelD #: 1358 14 HSBC Securities is a licensed broker-dealer regulated by the Securities and Exchanges Commission (SEC). HSBC Finance Corporation, formerly subprime lender Household International, provides credit cards, automobile loans, consumer lending, and insurance products, and is overseen by several U.S. regulators including the Consumer Financial Protection Bureau. HNAH also owns an Edge Act corporation in Miami, HSBC Private Bank International. 17 The Edge Act allows U.S. national banks to form U.S. subsidiaries designed to engage solely in international banking operations, including holding deposits for non-U. S. 1 8 persons. Edge Act corporations are chartered and regulated by the Federal Reserve. In addition, HNAH sponsors the HSBC Latin American International Center, also referred to as "HSBC Miami Offshore," in Miami. This center, like HSBC Private Bank International, is designed to help meet the needs of Latin American clients with banking needs in the United States. 19 HNAH owns several other subsidiaries as well, including HSBC Trust Company, N.A., of Delaware, and HSBC Bank Nevada, N.A., of Las Vegas, Nevada. HBUS Major Lines of Business. HBUS has six major lines of business in the United 20 States. The first is "Retail Banking and Wealth Management" which provides deposits, checking, savings, mortgages, loans, brokerage products, and certificates of deposit (CDs) to 2 1 customers. HSBC Premier is a product within the retail bank that provides services for more affluent clients. 22 The HBUS "Private Banking" offers wealth management services for high net worth individuals and families with deposits of at least $1 million. 23 HSBC Private Bank provides banking, investment, custody, wealth planning, trust and fiduciary, insurance, and philanthropic advisory services to its customers. 24 Clients receive a dedicated "relationship manager" to manage their Private Bank accounts. The HBUS "Commercial Banking" offers global banking services to financial 25 institutions, companies, governmental entities, and non-profit organizations worldwide. These services include deposits, checking, remote deposit capture, payments and cash management, pouch services, corporate loans and financing, merchant services, and insurance products. HBUS assigns each client a dedicated relationship manager to handle its accounts. 26 17 See "FAQs - HSBC Money Laundering Enforcement Action," attached to 10/6/2010 email from OCC James Vivenzio to OCC colleagues, "HSBC FAQs," OCC-PSI-00898845-857. 18 See the Edge Act, P.L. 102-242 (1919), codified at 12 U.S.C. § 611 et seq. 19 See HSBC Latin American International Center website, https://www.us.hsbc.com/l/2/3/hsbcpremier/miami- offshore. 20 HBUS Fact Sheet at 1-2. According to the OCC, HBUS has a total of 32 lines of business altogether. Subcommittee interviews of OCC examiners Joseph Boss (1/30/2012) and Elsa de la Garza (1/9/2012). 21 See https://www.us.hsbc.eom/l/2/3/hsbcpremier/miami-offshoreretail. 22 HBUS Fact Sheet at 1. 23 Id. at 2; Subcommittee interview of HSBC representatives (6/9/2011). 24 HBUS Fact Sheet at 2. 25 HBUS Fact Sheet at 1. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 20 of 339 PagelD #: 1359 15 The HBUS "Global Banking and Markets" line of business, with offices in more than 60 countries, provides a wide range of "tailored financial solutions" to major government, 27 corporate, and institutional clients. This line of business includes an extensive network of correspondent banking relationships, in which HBUS provides banks from other countries with U.S. dollar accounts to transact business in the United States. Due to its affiliates in over 80 countries, HSBC is one of the largest providers of correspondent banking services in the world. In 2010, it had about 2,400 correspondent customers, including for more than 80 HSBC 28 affiliates. Among other services, HSBC provides financial institution clients with access to the U.S. financial system by handling international wire transfers, clearing a variety of U.S. dollar instruments, including travelers cheques and money orders, and providing foreign exchange services. HBUS Payment and Cash Management (PCM) is a key banking division, located in 29 New York, that supports HBUS' correspondent relationships. In addition, as part of this line of business, until 2010, HBUS housed the Global Banknotes Department, which used offices in New York City, London, Hong Kong, and elsewhere to buy, sell, and ship large amounts of physical U.S. dollars. 30 The Banknotes Department derived its income from the trading, transportation, and storage of bulk cash, doing business primarily with other banks and currency exchange businesses, but also with HSBC affiliates. 31 In addition, for a number of years, HBUS held a contract with the U.S. Federal Reserve Bank of New York (FRBNY) to operate U.S. currency vaults in several cities around the world to assist in the physical distribution of U.S. dollars to central banks, large commercial banks, and businesses involved with currency exchange. 32 In June 2010, however, HBUS exited the wholesale U.S. banknotes line of business, later selling portions of the business to other banks. 33 It also did not renew its contract to operate FRBNY currency vaults. The HBUS "Global Asset Management" line of business offers worldwide investment management services to clients, and currently manages nearly $400 billion in assets. 34 It is one of the largest investment businesses in the world. Finally, "HSBC Insurance" provides a wide variety of insurance products to customers in the United States and Canada. 35 In addition to these major lines of business, in recent years, HBUS has become a leader in providing banking services to foreign embassies with a presence in the United States. HBUS 28 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335- 365, at 7. [Sealed Exhibit.] Subcommittee briefing by HSBC legal counsel (6/20/2012). 29 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 341-342 [Sealed Exhibit.]; Subcommittee interview of Michael Gallagher (6/13/2012). 30 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, OCC-PSI-00864335-365, at 341-342. [Sealed Exhibit.] 31 Id. at OCC-PSI-00864342. 32 See Form 10-Q filed by HSBC USA Inc. with the SEC for the quarter ending June 30, 201 1, at 9-10. 33 Id. In 2010, HSBC Holdings pic sold its U.S. wholesale banknotes business in Asia to United Overseas Bank Limited (UOB) for $1 1 million, and in 201 1, sold its European banknotes business to HSBC Bank pic. It recorded total closure costs of $14 million during 2010. Id. 34 HBUS Fact Sheet at 2. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 21 of 339 PagelD #: 1360 16 began this business after Riggs Bank and Wachovia Bank stopped providing those services in 2005, and embassies began looking for a new financial institution. 6 Through its correspondent banking and Payments and Cash Management (PCM) businesses, HBUS has become one of the largest facilitators of cash transfers in the world. Between 2005 and 2009, the total number of PCM wire transactions at HBUS grew from 20.4 million to 30.2 million transfers per year, with a total annual dollar volume that climbed from $62.4 trillion to $94.5 trillion. 37 In 2008, HBUS processed about 600,000 wire transfers per 38 week. In 2009, PCM was the third largest participant in the CHIPS wire transfer service which provides over 95% of U.S. dollar wire transfers across U.S. borders and nearly half of all wire transfers within the United States, totaling $1.5 trillion per day and over $400 trillion in 201 1. 39 HSBC Affiliates. HSBC has hundreds of affiliates located in over 80 countries. At least 80 HSBC affiliates have turned to HBUS for access to U.S. dollars and the U.S. financial system. These affiliates typically interact with HBUS by opening a correspondent account at HBUS headquarters in New York. Many use the account to clear U.S. dollars wire transfers; some use the account to cash U.S. dollar instruments like travelers cheques or money orders; still others use the account for foreign exchange purposes. In addition, some opened a separate account to buy or sell physical U.S. dollars as part of HBUS' wholesale banknotes business, until it was shuttered in 2010. HSBC affiliates have accounted for a large portion of HBUS' U.S. dollar activities. In 2009, for example, HSBC determined that "HSBC Group affiliates clear[ed] virtually all USD [U.S. dollar] payments through accounts held at HBUS, representing 63% of all USD payments processed by HBUS." 40 HSBC also calculated that, over an eight-year period, its U.S. dollar clearing business had increased over 200%, from processing an average daily amount of $185 billion in 2001, to $377 billion in 2009. 41 HBUS also executes transactions through HSBC affiliates in other countries. It has been estimated that, in 2009, HBUS processed 19.4 million transactions, involving $45.9 trillion, through HSBC affiliates. 42 36 See 1/30/2006 OCC Supervisory Letter regarding HBUS Embassy Banking, OCC-PSI-00107529-736, at 529-530; "HSBC to Open D.C. Branch, Pursue Embassy Clients," Washington Post, Terence O'Hara (10/5/2004)(quoting Riggs spokesperson: "As a service to our remaining embassy clients, Riggs is working closely with HSBC to ensure a smooth transition."), http://www.washingtonpost.com/ac2/wp-dyn/A7285-2004Oct4?language=printer. 37 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/ Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335- 365, at 7. [Sealed Exhibit.] 38 See 7/28/2008 OCC memorandum, "OFAC Examination - Payment and Cash Management (PCM)," OCC-PSI- 01274962, at 4. [Sealed Exhibit] 39 Id. See also The Clearing House website, "About CHIPS," http://www.chips.org/about/pages/033738.php. 40 See 9/9/2009 chart entitled, "HSBC Profile," included in "HSBC OFAC Compliance Program," a presentation prepared by HSBC and provided to the OCC, at HSBC OCC 8874197. 41 Id. at "USD Payment Statistics - Fact Sheet," HSBC OCC 887421 1. 42 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335- 365, at 7. [Sealed Exhibit.] Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 22 of 339 PagelD #: 1361 17 One of the largest HSBC affiliates is The Hongkong Shanghai Banking Corporation Ltd., which is incorporated in Hong Kong and is Hong Kong's largest bank. 43 Established in 1865, when Hong Kong was part of the British empire, it is the founding member of the HSBC Group, but now operates as a subsidiary of HSBC Holdings pic, the Group's parent corporation. With more than 71,400 employees, it oversees a network of hundreds of HSBC affiliates in 20 countries throughout Asia and the Pacific Region, including Australia, Bangladesh, China, India, Japan, Malaysia, New Zealand, Thailand, and Vietnam. 44 It is sometimes referred to in internal HSBC documents as HBAP, an abbreviation for HSBC Bank Asia Pacific. A second key affiliate is HSBC Bank Middle East Ltd. (HBME). Incorporated in Jersey in the Channel Islands and owned through a chain of subsidiaries reaching back to the Group's parent corporation in London, HBME oversees a network of financial institutions throughout the Middle East and North Africa. 45 With more than 5,000 employees, HBME provides banking services through nearly 45 branches in Algeria, Bahrain, Jordan, Kuwait, Lebanon, Oman, Pakistan, Qatar, and the United Arab Emirates. 46 In 1998, HSBC Group established "HSBC Amanah," a "global Islamic financial services division" designed to "serve the particular needs of Muslim communities" in compliance with Islamic law. 47 HBME offers Amanah banking services to many of its clients in the Middle East and North Africa. A third affiliate discussed in this Report is HSBC Mexico SA. Banco (HBMX), the principal operating company of Grupo Financiero HSBC, SA. de C.V., which owns HSBC's businesses in Mexico. HSBC's Mexican group is one of Mexico's largest financial service conglomerates, with over 1,000 branches throughout the country, nearly $2 billion in assets, and 48 over 8 million clients. HSBC purchased HBMX in 2002, when it operated under the name of Banco Internacional, SA. and was part of Grupo Financiero Bital, SA. de C.V. 49 HBMX and its Mexican parent are headquartered in Mexico City and together have about 19,000 employees. 50 See "Hongkong Shanghai Banking Corporation Limited Annual Report and Accounts 2011," at 2, http://www.hsbcxom.hk/l/PA_l_3_S5/content/about/financial-information/financial- reports/bank/pdf/201 lreport.pdf. 44 Id. 45 See "HSBC Bank Middle East Limited Annual Report and Accounts 201 1," http://www.hsbc.ae/l/PA_l_083Q9FJ08A002FBP5S00000000/content/uae_pws/pdf/en/annual_report_2011.pdf. 46 See id. at 32. See also "HSBC Wins its Eighth Best Cash Management Bank in the Middle East Award," http://www.hsbc. ae/l/2/about-hsbc/newsroom/eighth-best-cash-management, viewed 4/2/12; "HSBC Research Picks Up More Regional Awards," (1/12/12), http://www.hsbc.ae/l/PA_l_083Q9FJ08A002FBP5S00000000/content/uae_pws/pd^en/newsroom/euromoney- research-awards-jan-12.pdf, viewed 4/12/12. HSBC provides banking services in Saudi Arabia through both HSBC Saudi Arabia, in which it is a 49% shareholder, and Saudi British Bank (SABB), in which it is a 40% shareholder. See "HSBC Research Picks Up More Regional Awards," (1/12/12), http://www.hsbc.ae/l/PA_l_083Q9FJ08A002FBP5S00000000/content/uae_pws/pd^en/newsroom/euromoney- research-awards-jan-12.pdf, viewed 4/12/12. 47 See HSBC website, "About HSBC Amanah," http://www.hsbcamanah.com/amanah/about-amanah. 48 See HSBC website, Grupo HSBC Mexico, http://www.hsbc. com.mx/l/2/grupo, viewed 4/2/12. 49 See "HSBC Consuma la Adquision de GF BITAL," (1 1/25/02), http://www.hsbc. co m.mx/l/PA_l_l_S5/content/home_en/investor_relations/press_releases/infpress/hsbc_consuma. pdf. 50 See HSBC website, Grupo HSBC Mexico, http://www.hsbc. com.mx/l/2/grupo, viewed 4/2/12. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 23 of 339 PagelD #: 1362 18 HSBC Leadership. Over the last few years, HSBC leadership has undergone significant change. In 2010, HSBC Holdings pic appointed a new Chairman of the Board of Directors, Douglas J. Flint, replacing Stephen Green, who had become a U.K. Cabinet Minister. 51 A new Group Chief Executive was also selected, replacing Michael Geoghegan, who retired, with Stuart T. Gulliver. In 2012, HSBC Holdings pic also appointed a new Chief Legal Officer, Stuart Levey, former Undersecretary for Terrorism and Financial Intelligence at the U.S. Treasury Department. Mr. Levey replaced the Group's General Counsel, Richard Bennett. 52 Also in 2010, Sandy Flockhart, became Chairman of Europe, Middle East, Africa, Latin 53 America, Commercial Banking; as well as Chairman of HSBC Bank pic. Mr. Flockhart, who first joined HSBC in 1974, is an emerging markets specialist and, among other posts, headed HBMX in Mexico for five years, from 2002 to 2007. 54 He was also appointed to the HSBC Group Board of Directors in 2008, and became a director of HSBC Bank Middle East in July 2011. 55 HNAH Leadership. At HNAH, the U.S. bank holding company, the persons holding leadership positions have often overlapped with those of HNAH's key subsidiaries, HBUS, HSBC Securities, and HSBC Finance Corporation. HNAH's current Chief Executive Officer (CEO), for example, is Irene Dorner, who is also the CEO of HBUS. 56 Her immediate predecessor at HNAH, for less than a year, was Niall Booker, who was preceded by Brendan McDonagh, former Chief Operating Officer (COO) of HBUS. Before Mr. McDonagh, HNAH was headed by Siddharth (Bobby) N. Mehta, who was also head of HSBC Finance Corporation, but left the bank when HSBC Finance Corporation's subprime mortgage portfolio incurred huge losses during the recent financial crisis. The current HNAH COO is Gregory Zeeman; the current General Counsel is Stuart Alderoty; and the current Chief Auditor is Mark Martinelli, each of whom currently holds the same position at HBUS. 57 HNAH's Chief Risk Officer is Mark Gunton who holds the same position at both HBUS and HSBC Finance Corporation. HBUS Leadership. Over the last ten years, HBUS has undergone numerous changes in 58 leadership, with the head of the bank turning over four times. The current head is Irene Dorner 51 See "HSBC Announces New Leadership Team," (9/24/10), media release prepared by HSBC, http://www.hsbc.com/l/2/newsrooi'n/news/2010/hsbc-announces-new-leadership. 52 "HSBC appoints Chief Legal Officer," (1/13/12), media release prepared by HSBC, http://www.hsbcxom/l/2/newsroom/news/2012/chief-legal-officer. Mr. Levey held his position at the Treasury Department from July 2004 to February 201 1. Id. Mr. Bennett had headed HSBC Group's Legal and Compliance department since 1998; in 2010, he had become General Counsel. 53 See "HSBC Announces New Leadership Team," (9/24/10), media release prepared by HSBC, http://www.hsbc.eom/l/2/newsroom/news/2010/hsbc-announces-new-leadership. 54 See HSBC Group "Board of Directors," http://www.hsbc.eom/l/2/about/board-of-directors (describing Mr. Flockhart as "a career banker, being an emerging markets specialist with over 35 years' experience with HSBC in Latin America, the Middle East, US and Asia"). 55 Id. 56 See "Leadership: HSBC North America Holdings Inc.," https://www.us.hsbc.eom/l/2/3/personal/inside/about/corporate-information/leadership/hnah. 57 Id. 58 Information on HBUS' leadership is taken from its SEC annual reports. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 24 of 339 PagelD #: 1363 19 who serves as HBUS' Chairman of the Board, President, and CEO. She was appointed to those positions in 2010, after having served as the CEO of HSBC Bank Malaysia and as a director on the HBUS Board. Her immediate predecessor was Paul J. Lawrence who headed HBUS from 2007 to 2010. His predecessor was Sandy L. Derickson who served in the post for less than one year and left the bank along with Mr. Mehta after HSBC Finance Corporation, where he was second-in-command, incurred substantial losses. His predecessor was Martin J.G. Glynn who headed HBUS from 2003 to 2006, and then retired. HBUS has a six -person Board of Directors. Its current members are Ms. Dorner; William R.P. Dalton, former CEO of HSBC Bank pic in London; Anthea Disney, former Executive Vice President of NewsCorporation; Robert Herdman, former SEC Chief Accountant; Louis Hernandez, Jr., CEO of Open Solutions Inc.; and Richard A. Jalkut, CEO of TelePacific Communications. Within HBUS, the current Chief Operating Officer (COO) is Gregory Zeeman. 59 His immediate predecessor was David Dew 60 who was preceded by Brendan McDonagh, who served as the COO from 2004 to 2006. Some other key HBUS executives are Marlon Young, the head of Private Banking Americas; Kevin Martin, the head of Retail Banking and Wealth Management; and Mark Watkinson, the head of Commercial Banking. 61 Since 2007, the bank's Chief Auditor has been Mark Martinelli. From 2000 to 201 1, the head of HBUS Payments and Cash Management (PCM) was Michael Gallagher. The head of Global Banknotes, from 2001 to 2010, was Christopher Lok. HBUS' current General Counsel is Stuart A. Alderoty. 62 His predecessor was Janet Burak who served as the bank's General Counsel from 2004 to 2010. In 2007, she was also made the Regional Compliance Officer for North America. B. HBUS AML Program The compliance and anti-money laundering (AML) programs at HBUS have undergone continual organizational and leadership changes since 2005. In April 2003, the Federal Reserve and New York State Banking Department, which oversaw HBUS' predecessor bank, cited the bank for multiple, severe AML deficiencies and required it to enter into a written agreement to See "Leadership: HSBC Bank USA, N.A.," https://www.us.hsbc.conVl/2/3/personal/inside/about/corporate- information/leadership/hbus. 60 Mr. Dew served as HBUS COO from March 2007 to 2008; prior to that, he served for a month as HBUS Chief Administrative Officer from February 2007 to March 2007; prior to that he served as audit head at HUSI and HSBC North America Inc. from 2006 to 2007, and as audit head of HSBC North America Holdings Inc. from 2004 to 2007. Mr. Dew currently works as Managing Director of the Saudi British Bank which is 40% owned by HSBC. Subcommittee interview of David Dew (3/5/2012). 61 See "2011 HSBC Annual Report," http://www.us. hsbc.com/l/2/3/personal/inside/about/corporate- information/leadership/hbus, viewed 3/23/12. 62 See "Leadership: HSBC Bank USA, N.A.," https://www.us.hsbc.com/l/2/3/personal/inside/about/corporate- information/leadership/hbus. 63 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00000230- 259, at 256. [Sealed Exhibit.] Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 25 of 339 PagelD #: 1364 20 revamp and strengthen its AML program. It was at that time that HBUS renamed itself and converted to a national bank charter under the supervision of the OCC. During its first year under OCC supervision, HBUS reorganized its AML program, revamping its AML controls, country and client risk assessment criteria, Know Your Customer (KYC) due diligence requirements, and systems for detecting and reporting suspicious activity. 65 HBUS also acquired a new system for monitoring account activity, called the Customer Activity Monitoring Program (CAMP) and established criteria to produce alerts requiring additional reviews. In addition, HBUS created a system of KYC client profiles with standard due diligence information requirements for each client and which was updated on a regular basis and had to be approved by compliance and other bank officials for an account to be kept open. HBUS also established a Financial Intelligence Group to conduct enhanced due diligence reviews. Although the OCC gave positive reviews to the bank's initial efforts, 66 by 2010, the OCC issued a lengthy Supervisory Letter again citing the bank for numerous AML deficiencies and requiring HBUS to revamp its AML program a second time. In response, the bank issued an action plan to correct identified problems. HBUS has, for example, acquired a new AML monitoring system, NORKOM to replace CAMP, and is working to refine its parameters for detecting suspicious activity. In its first month of operation, NORKOM detected more than 100,000 transactions needing further review, demonstrating its ability to catch many transactions that went previously unchecked under CAMP. HBUS has also revamped its approach to HSBC affiliates, which make up an important segment of HBUS' correspondent banking, wire transfer, and cash management businesses and previously operated without due diligence controls and at times with minimal or no AML monitoring. Among other changes, HBUS now requires all subsidiaries to conduct due diligence on all other HSBC affiliates, including by using internal audit information identifying their AML risks and AML controls; identifies affiliates posing high AML risks; and treats them accordingly, thus ending all policies exempting affiliates from standard AML account and wire transfer monitoring. In addition, HBUS has revamped its country and client risk assessment criteria, which now identify high risk clients in a more robust manner; reviewed its correspondent banking business to reduce the number of high risk financial institutions; and closed some high risk business lines including its U.S. banknotes program. HBUS has also hired new AML leadership and significantly expanded its AML staffing and resources. HBUS currently employs over 1,000 compliance personnel. 67 Some of HBUS' changes have been criticized by the OCC as inadequate. HBUS has been informed by the OCC that it must do additional work on its monitoring system in order to implement the requirements of the 2010 Cease and Desist Order. The individual hired by HBUS to serve as its Chief Compliance Officer was asked to leave by the bank shortly after starting in See HSBC Bank USA, Federal Reserve Bank of New York, and New York State Banking Department , Docket No. 03-012-WA/RB-SM (Board of Governors of the Federal Reserve System, Washington, D.C.), Written Agreement (4/30/2003), OCC-PSI-00907803-811. 65 See OCC Report of Examination of HBUS, for the examination cycle ending March 31, 2005, OCC-PSI- 00423650. [Sealed Exhibit.] 66 Id. at 10-11 (describing the formal agreement). 67 See 7/10/2012 HSBC Group News, "HSBC to Testify at U.S. Senate Hearing." letter by HSBC Group Chief Executive Stuart Gulliver, PSI-HSBC-76-000 1-002, at 002. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 26 of 339 PagelD #: 1365 21 2010. Both HBUS and the OCC will have to work hard to ensure that the latest round of changes will produce a better AML outcome than the changes made in 2004. (1) HBUS Compliance and AML Leadership Over the last five years, HBUS has experienced high turnover in its Compliance and AML leadership, making reforms difficult to implement. Since 2007, HBUS has had four Compliance heads and five AML directors. Currently, both positions are held by the same person, Gary Peterson. Mr. Peterson has extensive AML experience and was hired in 2010, to be the AML director, but after the Compliance head was asked to leave in 2010, has since held both posts. In 2012, Mr. Peterson is expected to relinquish his duties as AML director to his deputy, Alan Schienberg, so that the top Compliance and AML positions at HBUS will each have a full time professional. 68 The top compliance position at HBUS is the Chief Compliance Officer who oversees all compliance issues for the bank. In the AML field, HBUS has specified two posts which have been held by the same person, the Anti-Money Laundering (AML) Director who is tasked with ensuring bank compliance with U.S. AML laws and regulatory requirements. 69 HBUS' Compliance and AML leadership positions were relatively stable until 2007, after which the bank has struggled to hire and retain experienced compliance professionals. HBUS' Chief Compliance Officer from 2000 to 2008 was Carolyn Wind. Prior to that position, Ms. Wind worked for Republic Bank of New York as a compliance officer and, before that, as an OCC bank examiner. For the first three years she held the job, Ms. Wind also served as the AML Director. In 2003, the bank hired a separate AML Director, Teresa Pesce, who served in that post nearly four years, from 2003 to March 2007. Before taking the position at the bank, Ms. Pesce was a Federal prosecutor with the U.S. Attorney's Office in New York. Ms. Pesce left the bank in 2007, after which Ms. Wind headed both the Compliance and AML Compliance functions until she left the bank in 2008. As discussed below, Ms. Wind was dismissed by HBUS after raising the issue of inadequate AML resources with the audit committee of the board of directors of the bank's holding company, HNAH. In 2007, as part of a "Compliance Transformation Initiative," HSBC established a North 70 America Compliance department at HNAH headed by a Regional Compliance Officer. HNAH appointed Janet Burak, then Regional Legal Department Head for North America, to also serve as the Regional Compliance Officer; she held both positions from 2007 to 20 10. 71 At the time, HSBC Group Compliance head David Bagley expressed concern about combining the two roles, 79 arguing that each required too much effort for a single person, but was overruled. Two years 68 See HSBC website, "Leadership: HSBC Bank USA, N.A.," https://www.us. hsbc.com/l/2/3/personal/inside/about/coiporate-information/leadership/hbus. 69 The AML Director also serves as HBUS' Bank Secrecy Act Compliance Officer. 70 See also Federal Reserve, at BOG-A-205485. 71 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/ Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335- 365, at 27. [Sealed Exhibit.] 72 See 6/21/2007 email from HSBC David Bagley to HSBC Richard Bennett, HSBC OCC 8873871-5 (conveying to HSBC Group's most senior legal counsel, Richard Bennett, the concern of HBUS compliance personnel about "the Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 27 of 339 PagelD #: 1366 22 later, in March 2009, the Federal Reserve issued a negative critique of Ms. Burak's performance, ■71 noting in particular that she did not have an adequate understanding of AML risk or controls. The OCC also later criticized her performance as well as the decision to combine the regional legal and compliance roles, noting in 2010, that Ms. Burak "has had to balance a wide range of legal and compliance duties, including establishing the strategic direction for both functions and representing both functions on senior committees at the Group level." 74 The OCC stated that, as a consequence, Ms. Burak had "not regularly attended key committee or compliance department meetings" and had failed to keep herself and other bank executives "fully informed about issues and risks within the BSA/AML compliance program." 75 It also placed some of the blame at her feet for a recently discovered backlog of 17,700 alerts indicating possible suspicious activity at the bank, which had not been reviewed, noting that "[b]acklogged alerts needed to receive the highest level of attention from senior bank management at a much earlier stage to ameliorate the problem." 76 Soon after this critique, Ms. Burak left the bank. In the two years she held the regional posts, Ms. Burak oversaw three functional compliance teams at HNAH called "Compliance Advisory," "Compliance Center of Excellence," and "Compliance Shared Services Utility." 77 Each team was headed by a senior Compliance manager: Curt Cunningham, Anthony Gibbs, and Lesley Midzain. Ms. Midzain was hired in 2007 to replace Carolyn Wind and so worked, not only for HNAH, but also for HBUS as both its Compliance head and AML director. She held these compliance posts for two years, from 2007 until 2009. Prior to being placed at the helm of the bank's AML program, Ms. Midzain had no professional experience and little familiarity with U.S. AML laws. In December 2008, HNAH's regulator, the Federal Reserve, provided a negative critique of Ms. Midzain's management of the bank's AML program. The Federal Reserve wrote that Ms. Midzain did "not possess the technical knowledge or industry experience capability of one person to manage a very large legal function and a compliance function" and that "compliance will be pushed down below Legal"). See also 7/28/2010 email from HSBC David Bagley to HSBC Michael Geoghegan, HSBC OCC 8873871-75 (expressing to HSBC CEO Michael Geoghegan, that with regard to the 2007 decision to combine the two roles into one: "I fully accepted that Brendan [McDonagh], Paul [Lawrence] and Richard [Bennett] had the right to make this call, although as I said to you in Vancouver I now wish I had been more vociferous and in the current way my role operates 1 am confident that I would have a far stronger say."). 73 The March 2009 Federal Reserve's Summary of Ratings stated: "Interviews conducted as part of our recent governance review revealed that Janet Burak, HNAH Legal and Compliance chief risk officer has only broad understanding of BSA/AML risk and relies on the HNAH BSA/AML officer [Midzain] to manage the risk. . . . Midzain, as previously stated has weak BSA/AML knowledge and industry experience. Burak's heavy reliance on the inexperienced Midzain is a concern. An example of Burak's limited management oversight of BSA/AML was revealed when we recently met with her to clarify a few items from our Governance review she was unable to respond to the question about the distribution and the purpose of annual AML statements. She subsequently communicated via email that she does not review the annual AML statements provided to her by the HNAH/BSA/AML officer (Midzain). Burak forwards the statements to Group." 3/25/2009 "Summary of Ratings for HSBC North America Holdings," Federal Reserve Bank of Chicago, OCC-PSI-00899234. 74 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 27. [Sealed Exhibit.] 75 Id. 76 Id. 77 Id. See also Federal Reserve, at BOG-A-205485. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 28 of 339 PagelD #: 1367 23 to continue as the BSA/AML officer." It noted that she "was interviewed by OCC examiners from another team and they supported the conclusion of the OCC resident staff that Midzain's knowledge and experience with BSA/AML risk is not commensurate to HNAH's BSA/AML 79 high risk profile, especially when compared to other large national banks." In 2009, the OCC also concluded that Ms. Midzain did not have the requisite AML expertise for her position. An OCC Supervisory Letter echoed the criticisms leveled earlier by the Federal Reserve: "Ms. Midzain was selected as the Compliance Director and BSA Officer although she does not have the qualifications or the experience to manage a BSA program at an institution with the size and amount of BSA compliance risk that HBUS has. She is a Canadian lawyer (a barrister and solicitor) who formerly worked for HNAH. She is also a member of Group's executive development program. . . . Ms. Midzain's assignment as HBUS' BSA Officer and Compliance Director has been her first assignment outside of Canada as a part of that program. . . . During its 2009 compliance management examination, the OCC determined that Ms. Midzain lacked the experience and expertise to be the BSA Officer, and the OCC included an MRA in its supervisory letter that required the bank to strengthen its BSA/AML compliance leadership by hiring a BSA Officer who is highly qualified and very experienced." 80 In response to the Federal Reserve and OCC criticisms, HBUS removed Ms. Midzain from the AML post, but retained her as head of HBUS ' Compliance department. In the fall of 2009, HBUS hired a new AML Director, Wyndham Clark, a former U.S. Treasury official, who assumed the post in the middle of an intensifying AML examination by the OCC and a host of serious AML problems facing the bank. Mr. Clark was required to report to Curt Cunningham, an HBUS Compliance official who freely admitted having no AML expertise, 81 and through him to Ms. Midzain, whom the OCC had also found to lack AML expertise. Shortly after he arrived, 82 Mr. Clark began requesting additional resources. After 30 days at the bank, Mr. Clark sent Mr. Cunningham a brief memorandum with his observations, noting that HBUS had an "extremely high risk business model from AML perspective," had seen recent high turnover in its AML directors, and granted only limited authority to the AML director to remedy problems: "AML Director has the responsibility for AML compliance, but very little control over its success. Federal Reserve Bank of Chicago Summary of Ratings for HSBC North America Holdings, March 25, 2009, OCC-PSI-00899234. 79 Id. 80 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 28. [Sealed Exhibit.] 81 Id. at 28. 82 See, e.g., 10/19/2009 email exchange between HBUS Wyndham Clark and HBUS Debra Bonosconi, "OFAC resources," OCC-PS1-00 162661 (Mr. Clark commented after Janet Burak had recently approved three new compliance personnel positions, "Clearly a positive, although I understand that these were requested quite a while ago. 1 hope that isn't the typical response time." Ms. Bonosconi responded: "Oh, this was express time. Trust me on that. Usually the response is 'no.'"). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 29 of 339 PagelD #: 1368 24 Operate under 'crisis' mode, actions are reactive rather than forward thinking. AML Director unable to manage at high level. 83 Several AML Directors/BSA Officers in a short period of time." As he continued his work, Mr. Clark grew increasingly concerned that the bank was not effectively addressing its AML problems. In February 2010, Mr. Clark met with the Audit Committee of the HNAH board of directors and informed the committee that he had never seen a 84 bank with as high of an AML risk profile as HBUS. He also informed them that AML resources were "insufficient versus current risks and volumes," and the bank's systems and 85 controls were "inconsistent with AML risk profile." On May 10, 2010, Mr. Clark wrote to a senior HBUS Compliance official that with regard to the bank's AML compliance program, "With every passing day I become more concerned. . .if that's even possible." 86 In July 2010, less than a year after taking the post, Mr. Clark decided to resign. He sent an email to the head of HSBC Group Compliance David Bagley explaining that he did not have the authority or support from senior compliance managers needed to do his job as AML director: "[T]he bank has not provided me the proper authority or reporting structure that is necessary for the responsibility and liability that this position holds, thereby impairing my ability to direct and manage the AML program effectively. This has resulted in most of the critical decisions in Compliance and AML being made by senior Management who have minimal expertise in compliance, AML or our regulatory environment, or for that matter, knowledge of the bank (HBUS) where most of our AML risk resides. Until we appoint senior compliance management that have the requisite knowledge and skills in these areas, reduce our current reliance on consultants to fill our knowledge gap, and provide the AML Director appropriate authority, we will continue to have limited credibility with the regulators." 87 When asked about his experience at the bank, Mr. Clark told the Subcommittee that he did not 88 have either the authority or resources needed as AML director. After his departure, the bank hired Gary Peterson, who was then an AML consultant to the bank, appointing him as HBUS' new AML director. 10/15/2009 HBUS memorandum from Wyndham Clark to HNAH Curt Cunningham, "30 Day Observations and Recommendations Report from AML Director," HSBC PSI PROD 0065332. 84 Subcommittee interview of Wyndham Clark (1 1/30/201 1); 2/17/2010 "HNAH AML Program, Board Audit Committee Presentation," by HBUS Wyndham Clark to the Audit Committee of the HNAH board of directors, HSBC OCC 3800290. 85 2/17/2010 "HNAH AML Program, Board Audit Committee Presentation," by HBUS Wyndham Clark to the Audit Committee of the HNAH board of directors, HSBC OCC 3900290. 86 5/10/2010 email from HBUS Wyndham Clark to HBUS Anne Liddy, "AML Townhall," OCC-PSI-00672582. See also 5/9/2010 email from HBUS Wyndham Clark to HNAH Curt Cunningham, "AML Townhall," OCC-PSI- 00672571 ("Essentially AML decisions are now being made without AML SME [subject matter expertise]. This will be very apparent to the regulators."). 87 7/14/2010 email from HBUS Wyndham Clark to HSBC David Bagley, OCC-PSI-00676731. Mr. Clark formally left the bank in August 2010. Subcommittee interview of Wyndham Clark (1 1/30/201 1). 88 Subcommittee interview of Wyndham Clark (1 1/30/201 1). Mr. Clark told the Subcommittee that, prior to his leaving, the bank finally approved a number of new AML hires. Id. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 30 of 339 PagelD #: 1369 25 Around the same time that Mr. Clark left the bank in 2010, Ms. Midzain also departed, leaving open the post of Chief Compliance Officer. That post remained vacant until 201 1, when 89 HBUS hired Eric Larson. He left after fifteen months on the job. HBUS then asked Gary Peterson to serve, not only as HBUS' AML Director, but also as its Compliance head, and as HNAH's Regional Compliance Officer following Ms. Burak's departure in 2010. Mr. Peterson agreed and has served in all three posts since 2010. Altogether, these personnel changes meant that, over the last five years, HBUS has had four Chief Compliance Officers and five AML Directors. At HSBC Group, HBUS' parent organization, for nearly ten years, from 2002 to the present, David Bagley has served as the HSBC Group's head of Compliance. He is located in London and oversees both general and AML compliance issues. His second-in-command is Warren Learning, Deputy Head of HSBC Group Compliance, who has been in that position since January 1, 2007. Susan Wright serves as the head of HSBC 's AML efforts. She is also located in London and has served in that position for more than a decade. John Root is a senior Group Compliance officer who has concentrated on compliance and AML issues, in part in Mexico and Latin America. Compliance personnel work with Matthew King who has served as the head of HSBC Group Audit since 2002. (2) HBUS AML Program Federal law requires banks operating in the United States to have a minimum of four elements, an AML compliance officer in charge of the program, AML internal controls, AML training, and an independent testing of the AML program to ensure its effectiveness. 90 HBUS' AML program must address a wide range of AML issues, from customer due diligence, to monitoring account and wire transfer activity, to reporting suspicious activity to law enforcement. It must also cover a wide range of business lines and products, including Correspondent Banking, International Private Banking, Domestic Private Banking, Embassy Banking, Payment and Cash Management, and Banknotes services. Inadequate Staffing. Despite its high AML risks, millions of customers, and employment of more than 16,500 employees overall, from 2006 to 2009, HBUS' entire Compliance Department numbered less than 200 full time employees; its AML Compliance staff was a subset of that and also included staff in India. 91 HBUS personnel told the Subcommittee that inadequate AML staffing was one of the biggest problems they faced. OCC examinations also routinely identified inadequate staffing as a key AML problem, including with respect to Subcommittee interview of OCC Examiner Teresa Tabor (5/17/2012). 90 See 31 U.S.C. §5318(h); 12 C.F.R. §21.21. 91 Subcommittee briefing by HSBC legal counsel (6/30/201 1). 92 Subcommittee interview of HBUS Debra Bonosconi (1 1/17/201 1) (Ms. Bonosconi reported to the Subcommittee that staffing was her biggest issue and that by March 2008 it was evident that more staff was needed. She made several requests for additional resources); Subcommittee interview of HBUS Anne Liddy (2/22/2012) (Ms. Liddy made a request for resources to Carolyn Wind, but was told that there was no appetite to bring on additional staff); Subcommittee interview of HBUS Carolyn Wind (3/7/2012); Subcommittee interview of HBUS Teresa Pesce (3/30/2012) (Ms. Pesce asked for business to provide funding for more AML Compliance positions because Compliance did not have the money). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 31 of 339 PagelD #: 1370 26 unreviewed alerts, PCM processing, Correspondent Banking, OFAC reviews, Embassy Q7 OS Banking, and the Compliance Review Unit that tested the bank's AML controls. Bank documents show that Compliance and AML staffing levels were kept low for many years as part of a cost cutting measure. In 2007, HBUS announced a "1509 Initiative," to increase the bank's return on equity by 2009, largely through cost cutting measures. One component of the plan was to ensure that 2007 and 2008 headcounts remained flat. This hiring freeze caused HBUS Compliance and the AML staffing requests to be denied or unanswered. At one point, HBUS Compliance and AML management resorted to requesting temporary staff when persistent AML alert backlogs grew to unmanageable levels. In 2007, HBUS fired its longtime AML head after she raised resource concerns with the HNAH Audit Committee; an AML director hired in 2009 left after being denied the authority and resources he considered necessary to do his job. After the OCC issued its lengthy Supervisory Letter criticizing multiple aspects of HBUS' AML program, bank management began to significantly increase AML staff and resources. AML Staffing Problems. In 2006, HBUS Compliance was already struggling to "handle the growing monitoring requirements" associated with the bank's correspondent banking and cash management programs, and requested additional staff" In October 2006, HBUS Compliance officer Alan Ketley wrote that despite having very efficient processes, each month his Compliance team was "handling an average of 3,800 [alerts] per person and [was] becoming overwhelmed thus potentially placing the business and the bank at risk." 100 Despite requests for additional AML staffing, HBUS decided to hold staff levels to a flat headcount. 101 1509 Initiative and Hiring Freeze. In 2007, against the backdrop of losses stemming from its troubled acquisition of Household International and the beginning of the global financial crisis, HBUS launched the 1509 Initiative which sought to achieve a 15% return on equity for the 3/3/2010 OCC Supervisory Letter HSBC-20 10-03, "Backlog of Monitoring Alerts and Enhanced Due Diligence Requests," OCC-PSI-00851542-545. [Sealed Exhibits.] 94 3/18/2009 OCC Supervisory Letter HSBC-2008-40, "Payment and Cash Management BSA/AML Examination," OCC-PSI-00107624-625. [Sealed Exhibit.] 95 3/3/2009 OCC Supervisory Letter HSBC-2008-34, "Correspondent Banking BSA/AML Examination," OCC-PSI- 00107618-620. [Sealed Exhibit] 96 7/28/2008 OCC memorandum, "OFAC Examination - Payment and Cash Management (PCM)," OCC-PSI- 01274962; 1/20/2009 OCC Supervisory Letter HSBC-2008-41, "Office of Foreign Asset Control Examination," OCC-PS1-00000434-436. [Sealed Exhibits.] 97 See 3/19/2007 OCC Supervisory Letter HSBC-2006-30, "Government and Institutional Banking BSA/AML Examination," OCC-PSI-00107567-571; 1/30/2006 OCC Supervisory Letter regarding HBUS Embassy Banking, OCC-PSI-00107529-536. [Sealed Exhibits.] 98 See 6/14/2006 OCC Supervisory Letter HSBC-2006-16, "Compliance Review Unit Examination," OCC-PSI- 00000341-345. [Sealed Exhibit] 99 See 10/31/2006 email from HBUS Alan Ketley to HBUS Michael Gallagher, Denise Reilly, and Charles DelBusto, "Additional Compliance headcount needed to support PCM," HSBC OCC 0616340-43, at 341. 100 Id. at HSBC OCC 0616342. 101 See, e.g., 10/31/2006 email exchange between HBUS Michael Gallagher and HBUS Tony Murphy, Charles DelBusto, Alan Ketley, and others, "Additional Compliance headcount needed to support PCM," HSBC OCC 0616340-343; 9/25/2006 email exchange between HBUS Michael Gallagher and HBUS Teresa Pesce, Alan Ketley, Charles DelBusto, and others, "Additional monitoring resources," HSBC OCC 7688655-657. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 32 of 339 PagelD #: 1371 27 bank by 2009, primarily by cutting costs. One facet of the 1509 Initiative was the "$100 Million Dollar Cost Challenge," which set a goal of cutting costs of $100 million in 2007. 102 The hiring freeze began in September 2007, when HBUS Compliance had a headcount of 198 full time employees, one below its December 2006 level. 103 When Compliance sought to fill six open positions, David Dew, HBUS Chief Operating Officer (COO), informed Compliance head and AML director Carolyn Wind that the positions could not be filled: "This increase will be almost impossible to justify and therefore I must ask you to please cancel the open positions and ensure that your FTE as at 3 1 Dec 2007 does not exceed 199." 104 To make the case for increased staffing resources, in September 2007, HBUS Compliance personnel reached out to compliance peers at other banks and learned that at the three major banks that provided some information, each had a greater number of monitoring staff in the correspondent banking area than HBUS. 105 In addition, HBUS Compliance personnel noted that HBUS Compliance filed many fewer Suspicious Activity Reports (SARs) than its competitors; 106 while HBUS filed three to four per month in the correspondent banking area, its peers filed 30 to 75 per month, and one major international bank disclosed that it filed approximately 250 SARs per month. 107 Despite these statistics, the Compliance department and AML staff remained stagnant. Fired After Raising Staffing Concerns to Board. After being turned down for additional staff, Carolyn Wind, longtime HBUS Compliance head and AML director, raised the issue of inadequate resources with the HNAH board of directors. A month after that board meeting, Ms. Wind was fired. wz See HSBC internal presentation entitled, "1509," HSBC OCC 0616217-254, at 241-45. 103 9/14/2007 email from HBUS David Dew to HBUS Carolyn Wind, Janet Burak, and Kathryn Hatem, "HEADCOUNT," HSBC OCC 0616262. 104 Id. 105 On 9/6/2007, Mr. Ketley wrote: "Every bank that responded and provided information about monitoring staff has more than HBUS." 9/6/2007 email from HBUS Alan Ketley to HBUS Alan Williamson, Judy Stoldt, and George Tsugranes, "Correspondent survey," HSBC OCC 0616384-385. See also 9/6/2007 HBUS chart, "Correspondent Banking Survey," HSBC OCC 3400666. [Sealed Exhibit.] See also emails indicating HBUS Compliance personnel were not compensated at levels consistent with its competitors, and risked losing qualified personnel. See, e.g., 2/1/2007 email exchange among HBUS Carolyn Wind, HBUS Teresa Pesce and others, "MIP overages - URGENT," HSBC OCC 06163 14-3 16, at 3 14 ("We are not at market with our current competitors" and "[fjhese officers and AML officers can get new jobs in a heartbeat"); 2/27/2007 email from HBUS Karen Grom to HBUS Carolyn Wind, Denise Reilly, Teresa Pesce, David Dew and others, "HUSI Compensation Review," HSBC OCC 0616318 ("The banks who are approaching our employees have deep pockets and are willing to pay to get the talent. ... In many cases, we are paying under the 'market data point' (50 th percentile)." and "The offers from head-hunters are in some cases double base salaries and double bonusesf.]"). 106 9/6/2007 email from HBUS Alan Ketley to HBUS Alan Williamson, Judy Stoldt, and George Tsugranes, "Correspondent survey," HSBC OCC 0616384-385 (Mr. Ketley wrote "Our competitors all acknowledge filing more SARs than we do."); 9/6/2007 HBUS chart, "Correspondent Banking Survey," HSBC OCC 3400666. [Sealed Exhibit.] 107 8/27/2007 email from HBUS Alan Ketley to HBUS Michael Gallagher, Charles DelBusto, Chris Davies, and Alan Williamson, "Addressing negative information," HSBC OCC 7688584-587, at 587. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 33 of 339 PagelD #: 1372 28 On October 24, 2007, Ms. Wind met with the Audit Committee of the HNAH board of directors and, during the meeting, raised the staffing issue, particularly with respect to the Embassy Banking area which had been the subject of two recent OCC examinations uncovering severe AML deficiencies. Her supervisor, Regional Compliance Officer Janet Burak, also attended the Audit Committee meeting. The day after the meeting, in an email to HSBC Group Compliance head David Bagley, Ms. Burak expressed displeasure that Ms. Wind's comments had caused "inappropriate concern" at the Audit Committee: "I indicated to her [Ms. Wind] my strong concerns about her ability to do the job I need her to do, particularly in light of the comments made by her at yesterday's audit committee meeting .... I noted that her comments caused inappropriate concern with the committee around: our willingness to pay as necessary to staff critical compliance functions (specifically embassy banking AML support), and the position of the OCC with respect to the merger of 108 AML and general Compliance." A month after the board meeting, after seven years as HBUS' Compliance head, Ms. Wind was notified that she was being fired. In a January 22, 2008 letter to the head of HBUS Human Resources, Ms. Wind wrote: "I was told on November 30, 2007 that I was being terminated effective 2/28/08, due to the fact that the Board had lost confidence in me. ... If the Board has lost confidence in me based on my comments at the October, 2007 Audit Committee, why have I been allowed to continue to run this critical department without additional supervision or any direct follow-up from Group Compliance?" Ms. Wind also wrote: "David [Dew] and I disagree on the extent to which my organization can withstand cost cuts and still maintain an effective compliance risk mitigation program. I also believe in an open dialog with the Board and its committees, which may go against the desires of some in the organization." 109 When asked about this document, Ms. Wind told the Subcommittee that she believed she was fired for telling the HNAH board about the need for additional Compliance resources. 110 Hiring Freeze Continues. After her departure, the hiring freeze continued throughout 2008. 111 In February 2008, prior to her leaving the bank, Ms. Wind discussed the staffing freeze with HNAH COO Anthony Gibbs: 1U8 10/25/2007 email from Janet Burak to David Bagley, OCC-PSI-00704789. 109 January 22, 2008 letter from Carolyn Wind to Jeanne Ebersole, HSBC OCC 7730334. 110 Subcommittee interview of Carolyn Wind (3/07/2012). Anne Liddy also reported that Ms. Wind told her in 2007 that she had been terminated due to Ms. Wind raising resource concerns to the board's audit committee. Subcommittee interview of Anne Liddy (2/22/2010). Also see, Minutes of the Audit Committee Meeting, October 24, 2007, OCC-PSI-0070680. 111 On 1/17/08, Jeanne Ebersole, Executive Vice President HBUS Human Resources, wrote to the HBUS Executive Committee [EXCO], "Attached is a draft of the non-hiring freeze note to be sent to all GCBs 0, 1, 2 and the final headcount report for 2007 which we will discuss tomorrow at EXCO." 1/17/2008 email from HBUS Jeanne Ebersole to HBUS Chris Davies, David Dew, Janet Burak and others, "Draft Materials for EXCO," HSBC OCC 0616259-260, at 259. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 34 of 339 PagelD #: 1373 29 "HBUS Compliance has been required to manage down overall FTE [full time employees] while at the same time redeploying resources to priority needs. We also are in the midst of a 'hiring pause' which means that approval from appropriate EXCO members is required to fill any open position. I do not expect a lot of support for overall HBUS Compliance headcount increasing even if a portion of the time is allocated to other affiliates." 112 In June 2008, a senior PCM operations manager emailed senior HBUS Compliance official Anne Liddy about growing backlogs in the OFAC Compliance program: "I have put forth the suggestion of hiring up some first level checkers for OFAC processing in the GSC. . .we're strapped and getting behind in investigations (on OFAC cases) and have some of our key managers in the queues releasing items. . . I'm told I 113 cannot hire first level staff unless it's offshored. . ." An OCC examination later found that eight Compliance officers were under "rigorous pressure" to complete manual reviews of about 30,000 OFAC alerts per week. 114 In July 2008, however, HSBC Group senior management determined that the hiring freeze would continue to the end of the year. CEO Michael Geoghegan wrote to HNAH CEO Brendan McDonagh and others: "We have agreed that we will have a headcount freeze until the end of the year." 115 HBUS Compliance personnel, with the support of their business units, attempted to obtain an exception to the hiring freeze. In a September 2008 email, Michael Gallagher, PCM head at HBUS, requested additional Compliance staff, explaining: "I have expressed considerable concern for some time over the lack of resources both in compliance and within pcm [Payments and Cash Management] to adequately support kyc [Know Your Customer] and related regulatory requirements." 116 Lesley Midzain, then HBUS Chief Compliance Officer, echoed his concerns and requested four additional full time employees: "Given the hiring freeze in global businesses, I understand that it may also need approval by Paul Lawrence, but this has continued to be an area of notable risk and regulatory 117 attention and which needs some stabilization for Compliance resources." 112 2/12/2008 email from HBUS Carolyn Wind to HBUS Anthony Gibbs, Curt Cunningham, Denise Reilly and others, "Organizational Changes," HSBC OCC 0616264. 113 See 6/19/2008 email exchanges among HBUS Anne Liddy and HBUS Nancy Hedges, "OFAC processing in GSC's," HSBC OCC 0616349-350, at 349. 114 7/28/2008 OCC memorandum, "OFAC Examination - Payment and Cash Management (PCM)," OCC-PSI- 01274962 ("the bank's Compliance teams are under rigorous pressure to process alerts and determinfe] a disposition in a timely manner"). [Sealed Exhibit.] 115 7/23/2008 email from HSBC Michael Geoghegan to HNAH Brendan McDonagh and others, "2nd Half Costs," OCC-PSI-00727922. 116 See 9/4/2008 email exchanges among HBUS Michael Gallagher and HBUS David Dew, Lesley Midzain, Andrew Long, Chris Davies and others, "Kyc hires," HSBC OCC 0616352-356, at 356. When asked about this document, Mr. Gallagher said that Mr. Dew had informed him that broader concerns in the U.S. and at Group necessitated a flat headcount. Subcommittee interview of Michael Gallagher (6/13/2012). 117 Id. at HSBC OCC 0616354. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 35 of 339 PagelD #: 1374 30 After expressing concern over how additional hires would impact operating expenses, Mr. Dew, HBUS COO, asked Ms. Midzain if "a couple of temps for two months" would "do the trick." 118 Hiring did not improve during 2009. Wyndham Clark, who had been hired in 2009, as the new HBUS AML director, noted in an email that Janet Burak had recently approved three new compliance positions. He wrote: "Clearly a positive, although I understand that these were requested quite a while ago. I hope that isn't the typical response time." A senior PCM operations officer responded: "Oh, this was express time. Trust me on that. Usually the response is 'no.'" 119 The Subcommittee was told that in September 2009, the HBUS 120 Compliance department had 130 full time employees handling AML compliance issues. OCC Examination. During late 2009 and the first half of 2010, the OCC expanded and intensified its examination of the bank's AML program as a whole. Mr. Clark made increasing use of temporary employees and contractors to answer OCC inquiries and address AML deficiencies. In August, he left the bank. By then, he was using nearly 100 temporary employees and contractors and had requested 50 additional permanent full time Compliance personnel. 121 Even with those additional resources, the OCC's September 2010 Supervisory Letter identifying AML deficiencies at the bank criticized HBUS' failure "to provide adequate staffing and resources to implement and maintain a BSA/AML compliance program commensurate with the bank's high risk profile." The OCC Supervisory Letter also noted: "Management is still in the process of determining an appropriate level of resources as they consider recommendations from outside consultants and make strategic decisions about the 123 business and risk on a prospective basis." By October 2010, the Compliance department had increased to over 400 full time employees. 124 AML Monitoring Deficiencies. In addition to AML leadership problems and inadequate AML staffing, another key component of HBUS' AML program involved its monitoring systems. During the period reviewed by the Subcommittee, dating from 2004, HBUS used a monitoring system called the Customer Activity Monitoring Program (CAMP). This system had many limitations and often required manual reviews by HBUS Compliance and AML staff. By 2006, as indicated earlier, HBUS Compliance was already struggling to handle the monitoring alerts generated by the bank's growing correspondent banking and cash management 125 programs and described its personnel as "becoming overwhelmed." Backlogs of unreviewed alerts in different areas of the bank began to accumulate, including with respect to alerts lls Id. atHSBC OCC 0616352. 119 10/19/2009 email exchange between HBUS Wyndham Clark and HBUS Debra Bonosconi, "OF AC resources," OCC-PSI-00 162661. 120 Subcommittee briefing by HSBC legal counsel (6/30/201 1). 121 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 29. [Sealed Exhibit.] 122 Id. 123 Id. 124 Subcommittee briefing by HSBC and HBUS executives (6/26/2012). 125 See 10/31/2006 email from HBUS Alan Ketley to HBUS Michael Gallagher, Denise Reilly, and Charles DelBusto, "Additional Compliance headcount needed to support PCM," HSBC OCC 0616340-43, at 342. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 36 of 339 PagelD #: 1375 31 generated by CAMP monitoring of client accounts and wire transfer activity; alerts triggered by the OF AC filter on transactions by potentially prohibited persons identified on OFAC lists of terrorists, drug traffickers, and other wrongdoers; and alerts related to potentially suspicious activity in Embassy Banking accounts. With respect to the general CAMP system alerts for PCM, HBUS Compliance set a goal that no more than 2% of AML alerts should remain in the system for over 120 days without being resolved. In addition, the system notified increasingly senior management if the backlog exceeded certain thresholds. For example, when the CAMP alerts hit 3%, bank compliance officials like Anne Liddy were alerted; when it hit 4%, higher level compliance personnel such as AML director Lesley Midzain were notified; if the backlog hit 6%, HNAH's Regional 126 Compliance Officer Janet Burak was notified. In November 2009, the percentage of AML alerts in the system for longer than 120 days spiked from 4% in October to 9%. 127 The backlog remained at 9 or 10% for the next four months, from December 2010 to February 2010, and then stayed around 6 or 7% from March to May 2010. 128 In early 2010, as part of its expanded AML examination, the OCC discovered the CAMP backlog of more than 17,000 unreviewed alerts as 129 well as a backlog of requests for enhanced due diligence (EDD) reviews. On March 3, 2010, an OCC Supervisory Letter ordered the bank to eliminate the alert and EDD backlog by June 30, 130 2010. The bank met the deadline using "offshore reviewers in India, HBUS staff in Delaware, 131 HBUS temporary volunteers, [and] outside contractors." A subsequent review by the OCC, however, found "deficiencies in the quality of the work," and required an independent assessment. 132 The independent assessment found that 34% of the alerts supposedly resolved had to be re-done. As Ms. Wind reported to the board in October 2007, backlogs were also an issue in Embassy Banking. A 2008 OCC examination identified a backlog of over 3,000 alerts identifying potentially suspicious activity in Embassy accounts that had yet to be reviewed. 133 In response, HBUS initiated a concentrated effort to review and resolve those alerts prior to a followup OCC examination in July 2008. 134 The followup examination found a backlog of about 1,800 alerts, some of which dated from 2007. The OCC examiners recommended issuance of a c 126 "Bankwide KRI AML Transaction Monitoring Alert Aging - K02854," HSBC OCC 7688689. 127 Id. 128 Id. 129 3/3/2010 OCC Supervisory Letter HSBC-20 10-03, "Backlog of Monitoring Alerts and Enhanced Due Diligence Requests," OCC-PSI-00851542. [Sealed Exhibit.] 130 Id. 131 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 9. [Sealed Exhibit.] 132 Id. 133 8/14/2008 OCC memorandum, "Government and Institutional Banking Update," OCC-PSI-00899227-233, at 231. [Sealed Exhibit.] 134 July 31, 2008 Memorandum from HBUS Debra Bonosconi to HBUS David Dew, Lesley Midzain, and Cam Hughes. OCC-PSI-00409095. Also see 7/14/2008 Memorandum from HBUS Debra Bonosconi to HBUS David Dew, Lesley Midzain, Cam Hughes, "As shown in the chart below, we currently (as of 7/15) have a total of 1,793 open alerts which is a reduction of 1,519 from 3,312 on June 27 th . There are a total of 203 that are open in excess of 120 days and 147 open in excess of 90 days (350 combined) and we are concentrating our efforts on reducing those first. We are closing an average of 84 alerts daily (including Saturday) and based upon current projections, we should have total of 1,499 pending alerts when the OCC arrives on July 21, 2008." OCC-PSI-00285742 Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 37 of 339 PagelD #: 1376 32 Cease and Desist Order to the bank in part due to the backlog, but the OCC instead issued a Supervisory Letter, identified the backlog as a Matter Requiring Attention by the bank, and 135 136 required the backlog to be cleared by September 15, 2008. The bank met that deadline. A third category of alert backlog involved transactions that were stopped by the OF AC filter as possible violations of OFAC regulations. Each transaction had to be manually reviewed and resolved by two 4-person OFAC Compliance teams in New York and Delaware. In July 137 2007, HSBC introduced a new payment system, GPS, in the United States. The system had undergone several adjustments just prior to its launch, including changes to its OFAC filters, 138 which caused unexpectedly large backlogs. HBUS assigned a team to assist with clearing the backlog, but the problem still took weeks to resolve. In December 2009, HBUS' OFAC Compliance team in New York had accumulated a 139 backlog of greater than 700 OFAC alerts. The OFAC Compliance team requested five or six people from PCM for ten days to help clear the backlog. 140 PCM responded that it had no resources to loan, and suggested asking the Compliance team in Delaware for help. The OFAC Compliance team in New York indicated the Delaware Compliance staff was already "fully deployed" dealing with general alerts from the CAMP monitoring system: "We have considered all options at this point[;] the Compliance team in DE is already fully deployed dealing with wire camp alerts and bank examiner requests for the current exam. There is no bandwidth there at all[;] they are behind on the current alert clearing process which we are also dealing with." 141 Understaffed, HBUS Compliance and AML staff constantly battled alert backlogs while requesting additional resources. These requests, if answered, generally resulted in additional temporary staff dispatched only when backlogs grew to unmanageable levels. As the backlog increased, tensions grew, and in February 2010, Mr. Clark, the AML Director who had been on the job only a few months, wrote: "[W]e are in dire straights [sic] right now over backlogs, and decisions being made by those that don't understand the risks or consequences of their decisions!!!!" 142 135 See 9/4/2008 OCC Supervisory Letter HSBC-2008-07, "Government and Institutional Banking BSA/AML Examination," OCC-PSI-00107607-61 1. [Sealed Exhibit.] 136 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination -Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. §21.21)," OCC-PSI-00864335-365, at 9. [Sealed Exhibit.] 137 See, e.g., 7/29/2007 email from HBUS Andrew Long to HBUS Michael Gallagher, "draft strawman," HSBC OCC 7688680-682; 7/18/2007 email from HBUS Carolyn Wind to HBUS William Johnson, David Dew, Michael Gallagher, Andrew Long, David Bagley and others, "HBUS GPS Day 2 and 3 Update," HSBC OCC 7688676-678, at 677. 138 Id. 139 12/1 1/2009 email exchange among HBUS Camillus Hughes and HBUS Michael Gallagher, Charles DelBusto, Sandra Peterson, Thomas Halpin, Chris Davies, and Lesley Midzain, "OFAC Payments," HSBC OCC 7688668-670, at 670. 140 Id. 141 Id. at HSBC OCC 7688668. 142 2/26/2010 email from HBUS Wyndham Clark to HBUS Debra Bonosconi, OCC-PSI-00165898. In another email the next day, Mr. Clark wrote: "At this point the businesses are not accepting that they own the risk, I can Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 38 of 339 PagelD #: 1377 33 The problems with HBUS' AML monitoring system were not limited to the backlogs. Additional issues involved an array of problematic decisions on what clients and countries should be designated high risk and subject to enhanced monitoring; what accounts and wire transfer activity should be subject to or excluded from routine AML monitoring; what parameters should be used to trigger alerts, including dollar thresholds, key words or phrases, and scenario rules that combine specified elements; and what "negative rules" should be used to decrease the number of alerts that would otherwise be generated for review. 143 The OCC's September 2010 Supervisory Letter identified multiple problems with each of these elements of HBUS' AML monitoring systems. 144 Current Status of HBUS AML Program. In the two years since the OCC issued its September 2010 Supervisory Letter and both the OCC and Federal Reserve issued October 2010 Cease and Desist Orders to HBUS and HNAH regarding the many AML deficiencies in their programs, both HBUS and HNAH, as well as HSBC, have made commitments to strengthen their AML programs, including by directing more resources to compliance needs. HBUS told the Subcommittee that Gary Peterson will remain as its Compliance head, and his deputy will take over the duties of AML director, to ensure both positions have a full time executive. 145 HBUS also informed the Subcommittee that as of July 2012, it had increased its Compliance and AML staff to over 1,000 full time employees. 146 It is also in the process of replacing CAMP with an improved AML monitoring system, NORKOM. Additional reforms include scaling back its correspondent banking and embassy banking relationships by closing higher risk accounts, as well as closing its banknotes business in 2010. 147 With respect to HSBC affiliates, HBUS told the Subcommittee it has initiated due diligence reviews of all such affiliates to identify those that are high risk, enabled all affiliates to obtain internal audit findings and other information to improve affiliate risk assessments, ended any limits on the monitoring of affiliates, and increased affiliate information sharing to strengthen AML compliance. 148 think of one exception, making the difficult decisions and taking the necessary steps to mitigate the risk. My view is the risks are being ignored by the business, and they are simply waiting for compliance to tell them what the risks are and to convince them as to what actions need to be taken. If they don't know what the risks are, then why are they opening accounts or continuing with the relationship?" On the same day, Anne Liddy responded: "[W]e spend a lot of energy pushing our point and holding our ground and certainly Group member referred relationships/transactions have increased our HBUS risk." 2/27/2010 email exchange between HBUS Anne Liddy, Wyndham Clark, and Debra Bonosconi, OCC-PSI-00 165932. 143 See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335- 365, at 10-21. [Sealed Exhibit.] 144 Id. 145 Subcommittee briefing by HSBC and HBUS executives (6/26/2012). 146 Id. See also, 7/10/2012 HSBC Group News, "HSBC to Testify at U.S. Senate Hearing." letter by HSBC Group Chief Executive Stuart Gulliver, PSI-HSBC-76-000 1-002, at 002. 147 As of June 2012, HBUS had closed all banknotes accounts, 24 embassy accounts, and 326 correspondent relationships. In August 2010, as part of this review to exit relationships, HBUS CEO Irene Dorner noted that she was recommending closing relationships with 121 international banks that "do not meet either risk or return hurdles." 9/20/2010 email from Irene Dorner to Andrew Long and others, HSBC OCC 8876104-106. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 39 of 339 PagelD #: 1378 34 In addition, on April 30, 2012, HSBC Group issued a new Group Circular Letter (GCL) 120014, announcing the intention of the bank to use the highest global compliance standards for every HSBC affiliate. The HSBC GCL stated: "We must adopt and enforce the adherence to a single standard globally that is determined by the highest standard we must apply anywhere. Often, this will mean adhering globally to U.S. regulatory standards, but to the extent another jurisdiction requires higher standards, then that jurisdiction's requirements must shape our global standard." 149 This new GCL could represent a groundbreaking approach for the bank if it, in fact, pushes its affiliates toward uniform and high compliance standards. These reforms, like those announced in 2004 after the bank's last AML enforcement action, have the potential to resolve the AML deficiencies at the bank and push HBUS to an improved level of AML compliance. While HBUS has committed to making major changes, the bank made similar commitments under the 2003 enforcement action, which the OCC lifted in 2006, after which the bank's AML program quickly deteriorated. On many occasions since then, HBUS responded to AML problems identified by the OCC by instituting new policies and procedures that appeared to be effective remedies. However, it has often been the case that regulators would subsequently cite HBUS for failing to comply with its own policies and procedures. In 2006, for example, when the OCC lifted the AML enforcement action, HBUS had already incurred over 30 AML-related Matters Requiring Attention, many of which cited AML problems similar to those that had formed the basis of the written agreement. In addition, not all of the AML reforms proposed since 2010 have proceeded smoothly. The new compliance head hired by the bank left after fifteen months. The bank's new monitoring system has been the subject of OCC criticisms aimed at whether its monitoring parameters have been correctly set to identify suspicious activity and provide adequate AML oversight of client account and wire transfer activity. 150 While the recent GCL could represent an important advance in requiring bank affiliates to adhere to the highest AML standards globally, as this report documents, it can take months, if not years, for HSBC affiliates to come into compliance with HSBC GCL directives. The burden of proof is on HSBC Group to show that its latest directive is taking hold and its affiliates are complying with the highest AML stands, and on HBUS to show that it is moving from an ineffective AML program to one that safeguards the U.S. financial system from abuse. 14y GCL 120014 - HSBC Global Standards. 150 See 5/25/2012 OCC Supervisory Letter HSBC-2012-19, "Payments and Cash Management (PCM); Bank Secrecy Act and Anti-Money Laundering (BSA/AML) System Examination," PSI-OCC-3 7-0004. [Sealed Exhibit.] See also 6/25/2012 HSBC response letter, Supervisory Letter HSBC 2012-19 "Payments and Cash Management (PCM); Bank Secrecy Act and Anti-Money Laundering (BSA/AML) System Examination," HSBC-PSI-PROD- 0200315-341. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 40 of 339 PagelD #: 1379 35 ffl. HBMX: PROVIDING U.S. ACCESS TO A HIGH RISK AFFILIATE HBUS has opened correspondent accounts for approximately 80 HSBC affiliates around the world, providing them with access to the U.S. financial system through clearing U.S. dollar wire transfers, cashing U.S. dollar checks, buying and selling physical U.S. dollars, and other services. 151 Some of those HSBC affiliates operate in high risk countries, provide services to high risk clients, or offer high risk financial products. Until recently, HSBC Group policy, however, allowed its affiliates to assume that any HSBC affiliate owned 50% or more by the Group met Group AML standards, were low risk, and required no due diligence prior to opening 1 52 a correspondent account. In conformance with that HSBC Group policy, for years, HBUS did not conduct any due diligence analysis or risk assessment of an HSBC affiliate prior to supplying it with a U.S. account. HBUS took that approach, even though U.S. statutory and regulatory requirements explicitly direct U.S. banks to conduct due diligence prior to opening a correspondent account for any foreign financial institution, with no exception for foreign affiliates. 153 HBMX, an HSBC affiliate in Mexico, illustrates how providing a correspondent account and U.S. dollar services to a high risk affiliate increased AML risks for HBUS. HBMX was created when HSBC Group purchased a Mexican bank known as Bital in 2002. A pre-purchase review disclosed that the bank had no functioning compliance program, despite operating in a country confronting both drug trafficking and money laundering. For years, HSBC Group knew that HBMX continued to operate with multiple AML deficiencies while serving high risk clients and selling high risk products. HSBC Group also knew that HBMX had an extensive correspondent relationship with HBUS and that suspect funds moved through the HBMX account, but failed to inform HBUS of the extent of the AML problems at HBMX so that HBUS could treat HBMX as a high risk account. Instead, until 2009, HBUS treated HBMX as low risk. Contrary to its designation, HBMX engaged in many high risk activities. It opened accounts for high risk clients, including Mexican casas de cambios and U.S. money service businesses, such as Casa de Cambio Puebla and Sigue Corporation which later legal proceedings showed had been used on occasion, from 2005 to 2007 for Puebla and from 2003 to 2005 for 151 As of February 2010, HBUS had about 2,400 clients in its Payments and Cash Management (PCM) department. See 9/13/2010 OCC Supervisory Letter HSBC-2010-22, "Bank Secrecy Act/Anti-Money Laundering ('BSA/AML') Examination - Program Violation (12 U.S.C. § 1818(s); 12 C.F.R. § 21.21)," OCC-PSI-00864335-365, at 7. [Sealed Exhibit.] In June 2012, HBUS had a total of nearly 1,200 correspondent clients, of which 80 were HSBC affiliates. The HSBC affiliates had 395 HBUS accounts, of which 7 or 8 related to HBMX. Subcommittee briefing by HSBC legal counsel (6/20/2012). 152 See, e.g., 4/9/2010 memorandum from OCC legal counsel to OCC Washington Supervision Review Committee, "Order of Investigation - HSBC Bank USA, N.A., New York, NY," OCC-PSI-00899482-485, at 2 (citing HBUS's 12/1/2008 AML Procedures Manual at 12: "The only exception to the KYC Profile requirement is any client who is an HSBC Group affiliate in which HSBC has an ownership interest of 50% or more."). After the Setember 2010 OCC Supervisory Letter criticizing its practice, HSBC Group changed its policy and now requires all affiliates to perform due diligence on all other affiliates. 153 See, e.g., 4/9/2010 memorandum from OCC legal counsel to OCC Washington Supervision Review Committee, "Order of Investigation - HSBC Bank USA, N.A., New York, NY," OCC-PSI-00899482-485, at 2 ("The Bank is obligated to conduct due diligence, and, where necessary, EDD [Enhanced Due Diligence], on foreign correspondent accounts. 31 U.S.C. § 5318(i)(l). ... Section 53 1 8(i) does not exempt foreign correspondent accounts that a bank maintains for its affiliates."). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 41 of 339 PagelD #: 1380 36 Sigue, to launder funds from illegal drug sales in the United States. HMBX also offered high risk products, including providing U.S. dollar accounts in the Cayman Islands to nearly 50,000 clients with $2.1 billion in assets, many of which supplied no KYC information and some of which misused their accounts on behalf of a drug cartel. HBMX was also the single largest exporter of U.S. dollars to HBUS, transferring over $3 billion in 2007 and $4 billion in 2008, amounts that far outstripped larger Mexican banks and other HSBC affiliates. Mexican and U.S. law enforcement and regulatory authorities expressed concern that HBMX's bulk cash shipments could reach that volume only if they included illegal drug proceeds that had been brought back to Mexico from the United States. In addition, for a three-year period from mid-2006 to mid-2009, HBUS failed to conduct any AML monitoring of its U.S. dollar transactions with HSBC affiliates, including HBMX, which meant that it made no effort to identify any suspicious activity, despite the inherent risks in large cash transactions. 154 HBMX conducted these high risk activities using U.S. dollar correspondent and banknotes accounts supplied by HBUS. HBMX used those accounts to process U.S. dollar wire transfers, clear bulk U.S. dollar travelers cheques, and accept and make deposits of bulk cash, all of which exposed, not only itself, but also HBUS, to substantial money laundering risks. HBMX compounded the risks through widespread, weak AML controls, while HBUS magnified them by omitting the due diligence and account monitoring it applied to other accounts. HSBC Group also compounded the AML risks by failing to alert HBUS to HBMX's ongoing, severe AML deficiencies. A. HSBC Mexico In November 2002, HSBC Group purchased Mexico's fifth largest bank, Banco Internacional, S.A., then part of Grupo Financiero Bital, SA. de C.V. (Bital), for about $1.1 billion. 155 At the time of the purchase, Bital had roughly 6 million customers and 15,400 staff. 156 This acquisition significantly increased HSBC's banking presence in Mexico. 157 HSBC later changed the name of the bank to HSBC Mexico SA. Banco (HBMX) and the name of the holding company to Grupo Financiero HSBC, SA. de C.V. (GF HSBC). GF HSBC is now one of Mexico's largest financial service conglomerates, owning not only HBMX but also a network of other financial firms. 158 HBMX currently has over 1,100 branches, $2 billion in assets, and 1M See 9/13/2010 OCC Supervisory Letter HSBC 2010-22, OCC-PSI-00000230, at 2. [Sealed Exhibit.] 155 See "HSBC Consuma la Adquision de GF BITAL," (1 1/25/02), http://www.hsbc. co m.mx/l/PA_l_l_S5/content/home_eMnvestor_relations/press_releases/inlpress/hsbc_consuma. pdf; "HSBC Buys Mexican Bank Bital," CNN.com (8/25/2002), http://archives.cnn.com/2002/BUSINESS/asia/08/21/uk.hsbc. 156 8/21/2002 "HSBC agrees to acquire Grupo Financiero Bital," HSBC press release, http://www.hsbc.eom/l/2/newsroom/news/2002/hsbc-agrees-to-acquire-grupo-financiero-bital. 157 Two years earlier, in 2000, HSBC had acquired a smaller bank in Mexico, Republic National Bank of New York (Mexico) SA. See 10/21/201 1 "Doing Business in Mexico," HSBC publication, at 34, http://www.hsbc.eom/l/content/assets/business_banking/l 1 1021_doing_business_in_mexico.pdf. 158 Among other entities, GF HSBC owns a securities firm, insurance company, and pension fund. See HSBC Mexico website, "Grupo HSBC Mexico," http://www.hsbc. com.mx/l/2/grupo. Former HBMX head Paul Thurston told the Subcommittee that HBMX experienced rapid growth from its purchase in 2002. Subcommittee interview of Paul Thurston (5/1/2012). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 42 of 339 PagelD #: 1381 37 over 8 million clients. 159 HBMX and its Mexican parent are headquartered in Mexico City and together have over 19,000 employees. 160 HSBC typically refers to its Mexican operations as HSBC Mexico. Since the purchase of Bital, three persons have served as the head of HSBC Mexico. The first was Alexander (Sandy) Flockhart who served as Chairman and Chief Executive Officer (CEO) of HBMX, and later also as CEO of HSBC s Latin America operations, from 2002 to 2007. 161 After he was made Latin American regional head, 162 Paul Thurston took the post of HSBC Mexico CEO and later also served as the HSBC Latin America CEO. 163 Mr. Thurston headed the Mexico operations for just over a year, from February 2007 to May 2008. When he was promoted and relocated to London, 164 Luis Pena Kegel became the new HSBC Mexico CEO and remains in that post today. 165 Mexican banks, including HBMX, are regulated by the Comision Nacional Bancaria y de Valores (CNBV) which oversees Mexican banks and securities firms. The Mexican central bank, Banco de Mexico, the Mexican Ministry of Finance, the Mexican Treasury Department (SHCP), and the Mexican Financial Intelligence Unit (FIU) also perform oversight functions. Mexico has a well-developed set of AML laws and regulations. Mexican regulators and law enforcement agencies work with their U.S. counterparts to combat drug trafficking and money laundering in both countries. HBMX is a large, sophisticated bank offering a full range of banking services, including deposits, checking, foreign exchange, commercial banking services, private banking and wealth management, and correspondent banking. HMBX offers correspondent accounts to a wide range of financial institutions. HBMX also maintains correspondent accounts for itself at other banks around the world, including in the United States. In 2002, at the time Bital was purchased, the bank had $647 million in correspondent banking deposits in Mexico, $700 million in the See 10/21/201 1 "Doing Business in Mexico," HSBC publication, at 6, http://www.hsbc. com/l/content/assets^siness_banMng/l 1 1021_doing_business_in_mexico.pdf; "Grupo HSBC Mexico," HSBC website, http://www.hsbc. com.mx/l/2/grupo. 160 See HSBC website, Grupo HSBC Mexico, http://www.hsbc. com.mx/l/2/grupo, viewed 4/2/12. 161 He was Group General Manager, Chairman and Chief Executive Officer of HBMX from 2002 to 2006, and Group Managing Director Latin America from 2006 to July 2007. See his biography on the HSBC website, http://www.hsbc.com/l/PA_esf-ca-app- content/content/assets/newsroom/media_kit/biogs/100223_sandy_flockhart.pdf. HSBC also has affiliates in Colombia, Panama, Peru, and Uruguay, among other Latin American locations. 162 In July 2007, Mr. Flockhart was appointed CEO of The Hongkong and Shanghai Banking Corporation Limited. See his biography on the HSBC website, http://www.hsbc. com/l/PA_esf-ca-app- content/content/assets/newsroom/media_kit/biogs/100223_sandy_flockhart.pdf. 163 In May 2008, Mr. Thurston was appointed head of GF HSBC, and later co-head of the Latin American Region. See his biography on the HSBC website, http://www.hsbc.eom/l/PA_esf-ca-app-content/content/ assets/newsroom/media_kit/biogs/101210_paul_thurston.pdf; "HSBC makes key international appointments," (4/15/2008), http://www.hsbc.eom/l/2/newsroom/news/2008/hsbc-makes-key-international-appointments. 164 In May 2008, Mr. Thurston was appointed Managing Director of UK Banking, in charge of HSBC's retail and commercial banking operations in the United Kingdom. See "HSBC makes key international appointments," (4/15/2008), http://www.hsbc.eom/l/2/newsroom/news/2008/hsbc-makes-key-international-appointments. 165 Mr. Pena was appointed head of GF HSBC. Id. Mr. Pena had previously headed Grupo Financiero Banorte and worked for 25 years at Banamax/Citigroup in Mexico. Id. Emilson Alonso was appointed Chief Executive of HSBC Latin America. Id. Case l:12-cv-04269-JBW-RML Document 36-3 1382 38 Filed 10/25/12 Page 43 of 339 PagelD #: Cayman Islands, and $143 million in New York. 166 According to CEO Paul Thruston, HBMX 1 67 experienced rapid growth in the early years after its acquisition. HBMX also operates a branch in the Cayman Islands, HSBC Mexico S.A, which was established by Bital in 1980, with authority to offer customers U.S. dollar accounts. 168 At its peak in 2008, the Cayman branch, which has no offices or employees of its own and is run by HBMX personnel in Mexico, had nearly 50,000 client accounts and assets totaling $2.1 billion. 169 HBMX has had an extensive relationship with HBUS, obtaining U.S. dollar services through both correspondent and banknotes accounts. HBMX used its HBUS correspondent account primarily to process international wire transfers and clear U.S. dollar monetary instruments such as travelers cheques. It also made use of HBUS' Remote Deposit Capture service which enabled HBMX to send monetary instruments to HBUS electronically for processing. HBMX interacted at times with the HBUS Payment and Cash Management (PCM) division regarding this account. In addition, HBMX interacted with the HBUS Global Banknotes division, until the Global Banknotes business was discontinued in 2010. HBMX used its banknotes account primarily to sell U.S. dollars received from its customers to HBUS, which HBMX typically transported to HBUS via armed car or aircraft. In one three-month period from November 2006 to February 2007, HBMX shipped nearly $742 million in U.S. dollars to HBUS; at its peak, HBMX exported $4 billion in bulk cash shipments to HBUS over the course of one year, 2008. Until it sharply curtailed its U.S. dollar services in Mexico in January 2009, HBMX shipped more U.S. dollars to HBUS than any other Mexican bank or HSBC affiliate. B. Mexico To understand HBMX's AML risks and, therefore, the risks HBUS incurred as its U.S. correspondent, it is necessary also to understand the AML risks in its home country, Mexico. From 2000 until 2009, HSBC Group and HBUS gave Mexico their lowest AML risk rating, despite overwhelming information indicating that Mexico was a high risk jurisdiction for drug trafficking and money laundering. In May 2009, HBUS suddenly increased its risk rating for Mexico by three notches, from its lowest to its highest risk level, where it remains today. 170 HSBC Group did not follow suit until 2012 when it raised its risk rating for Mexico from "cautionary" to "high risk." 171 '"""Compliance Due Diligence Trip by John Root: Bital (Mexico City) - 4-8 Nov02," prepared by HSBC John Root, HSBC OCC 8877802-807, at 5. 167 Subcommittee interview of Paul Thurston (5/1/2012). 168 This branch operates under a "Class B license," which is given by the Cayman Islands Monetary Authority to offshore banks authorized to do business only with non-residents of the Cayman Islands. See list of Cayman offshore banks at http://www.offshore-library.com/banking/cayman_islands/page_3; Subcommittee briefing by HSBC legal counsel on the Cayman accounts (4/20/2012). 169 See chart at HSBC OCC 8876787, attached to 9/12/2008 email from HSBC John Root to HSBC Adrian Cristiani, "Cayman Accounts," HSBC OCC 8876784. 170 See 4/9/2010 memorandum from OCC legal counsel to OCC Washington Supervision Review Committee, "Order of Investigation - HSBC Bank USA, N.A., New York, NY," OCC-PSI-00899482-485, at 484. 171 Subcommittee briefing by HSBC legal counsel (7/5/2012). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 44 of 339 PagelD #: 1383 39 (1) U.S. Assessment of AML Risk in Mexico INCSR Reports. In its annual International Narcotics Control Strategy Reports (INCSRs), which contain a country-by-country assessment of drug trafficking and money laundering risks, the U.S. State Department has consistently classified Mexico as a country of "primary" concern for money laundering, its highest risk rating. 172 In 2002, the State Department described Mexico's drug trafficking and money laundering risks as follows: "Mexico faces a myriad of drug-related problems that include the production and transshipment of illicit drugs, money laundering, consumption and illicit firearms trafficking. ... The Government of Mexico's (GOM) longstanding commitment to combat drug trafficking and related crimes resulted in tangible successes against the Arellano Felix Organization (AFO), the Carrillo Fuentes Organization (CFO), and the Gulf Cartel - widely considered the top three drug groups in the country. . . . Mexico remains a major supplier of heroin, methamphetamine, and marijuana, and the transit point for more than one half of the cocaine sold in the U.S. ... The industrial-scale drug trade has transformed narcotrafficking into one of Mexico's deadliest businesses. . . . These organizations have demonstrated blatant disregard for human life as the executions of law enforcement personnel, government officials, and innocent bystanders have increased. ... In recent years international money launderers have turned increasingly to Mexico for initial placement of drug proceeds into the global financial system." 173 The State Department also wrote: "The smuggling of bulk shipments of U.S. currency into Mexico and the movement of the cash back into the United States via couriers and armored vehicles, as well as through wire transfers, remain favored methods for laundering drug proceeds. Mexico's financial institutions engage in currency transactions involving international narcotics-trafficking proceeds that include significant amounts of U.S. currency or currency derived from illegal drug sales in the United States. Although drug trafficking continues to be the principal source of the laundered proceeds, other crimes including corruption, kidnapping, firearms trafficking, and immigrant trafficking are also major sources of illegal proceeds." 174 Equally negative assessments of Mexico's drug trafficking and money laundering risks appeared in the State Department's annual INCSR reports over the next four years. In 2006, for example, the State Department wrote: "The illicit drug trade continues to be the principal source of funds laundered through the Mexican financial system. Mexico is a major drug producing and drug-transit country. Mexico also serves as one of the major conduits for proceeds from illegal drug sales See, e.g., "2000 International Narcotics Control Strategy Report," U.S. Department of State (hereinafter "2000 INCSR"), at 621; 2002 INCSR at XII-60; 2006 INCSR Vol. II at 39; 2008 INCSR Vol. II at 62; 2012 INCSR Vol. II, at 33. 173 2002 INCSR, at V-27-V-28. 174 Id. atXII-161. Case l:12-cv-04269-JBW-RML Document 36-3 1384 40 Filed 10/25/12 Page 45 of 339 PagelD #: leaving the United States. Other crimes, including corruption, kidnapping, firearms trafficking, and immigrant trafficking are also major sources of illegal proceeds. The smuggling of bulk shipments of U.S. currency into Mexico and the movement of the cash back into the United States via couriers, armored vehicles, and wire transfers, remain favored methods for laundering drug proceeds. . . . According to U.S. law enforcement officials, Mexico remains one of the most challenging money laundering jurisdictions for the United States, especially with regard to the investigation of money laundering activities involving the cross-border smuggling of bulk currency from drug transactions. While Mexico has taken a number of steps to improve its anti-money laundering system, significant amounts of narcotics-related proceeds are still smuggled across the border. In addition, such proceeds can still be introduced into the financial system through Mexican banks or casas de cambio, or 1 75 repatriated across the border without record of the true owner of the funds." The State Department's relentlessly negative assessments of Mexico's drug trafficking and money laundering vulnerabilities continued unabated. In 2008, the State Department wrote that "U.S. officials estimate that since 2003, as much as U.S. $22 billion may have been 1 76 repatriated to Mexico from the United States by drug trafficking organizations." Four years later, in 2012, the State Department wrote that drug cartels were using Mexican and U.S. financial institutions to launder as much as $39 billion each year: "According to U.S. authorities, drug trafficking organizations send between $19 and $39 billion annually to Mexico from the United States." 177 Warnings. The State Department is far from the only governmental agency to have warned about the money laundering risks in Mexico. The U.S. Congress has held repeated hearings over the years highlighting money laundering and drug trafficking problems in Mexico. 178 Witnesses have included the U.S. Justice Department, Homeland Security Department, Federal Bureau of Investigations, Drug Enforcement Administration (DEA), Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department, Internal Revenue Service (IRS), Customs and Border Patrol, and Coast Guard, among others. From 1996 to 201 1, these hearings have painted the same grim picture drawn in the State Department's annual reports regarding the drug trafficking and money laundering threats in Mexico. 1/5 2006 INCSR, at 268-269. 176 2008 INCSR, at 327. 177 2012 INCSR, at 140. 178 See, e.g., "Money Laundering Activity Associated with the Mexican Narco-Crime Syndicate," U.S. House Banking and Financial Subcommittee on General Oversight and Investigations, Serial No. 104-72 (9/5/1996); "Drug Control: Update on United States-Mexican Counternarcotics Efforts," Senate Caucus on International Narcotics Control, S.Hrg. 106-60 (2/24/1999); "Federal Strategies to End Border Violence," Senate Judiciary Committee, S.Hrg. 109-556 (3/1/2006); "Antidrug Package for Mexico and Central America: An Evaluation," Senate Committee on Foreign Relations, S.Hrg. 1 10-3 11 (1 1/15/2007); "Escalating Violence in Mexico and the Southwest Border as a Result of the Illicit Drug Trade," House Judiciary Subcommittee on Crime, Terrorism, and Homeland Security, Serial No. 1 1 1-25 (5/6/2009); "Exploring Drug Gangs' Ever Evolving Tactics to Penetrate the Border and the Federal Government's Ability to Stop Them," Senate Homeland Security and Governmental Affairs Ad Hoc Subcommittee on Disaster Recovery and Intergovernmental Affairs, S.Hrg. 1 12-384 (3/3 1/201 1). Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 46 of 339 PagelD #: 1385 41 In addition, warnings about money laundering problems in Mexico have been directed specifically to financial institutions operating in the United States. In 2005, multiple U.S. agencies worked together to produce a U.S. Money Laundering Threat Assessment which identified thirteen key money laundering methods and specifically identified Mexico as a high risk jurisdiction for several of them, including bulk cash smuggling, misuse of money orders, and suspicious funds sent through money service businesses. 179 In 2006, FinCEN issued an advisory to all U.S. financial institutions to "better guard against an increasingly prevalent money laundering threat involving the smuggling of bulk U.S. currency into Mexico," warning in 1 80 particular against "the abuse of their financial services" by Mexican casas de cambio. The advisory explained that drug traffickers were smuggling bulk cash from the United States into Mexico, then depositing the funds with casas de cambios who were sending the cash back to the 181 United States via armored transport or by selling the U.S. dollars to U.S. banks. The advisory also warned about multiple wire transfers that "bear no apparent business relationship" with a particular casa de cambio, and U.S. deposits by casas de cambio of sequentially numbered monetary instruments. Wachovia Prosecution. Criminal prosecutions also alerted U.S. financial institutions to the money laundering problems in Mexico. In 2008, for example, news articles warned how Mexican drug cartels sent millions of dollars in illegal drug proceeds through a major U.S. 1 83 financial institution, Wachovia Bank. In 2010, the United States filed a deferred prosecution agreement detailing how Wachovia Bank had been used by Mexican foreign exchange businesses to launder at least $110 million in drug proceeds. 184 Filings in the case describe how, from 2003 to 2008, Wachovia Bank provided a variety of services for 22 Mexican casas de cambio (CDCs), despite evidence of suspicious activity. Those services included processing 185 numerous U.S. dollar wire transfers for deposit into bank accounts around the world; clearing large volumes of sequentially numbered U.S. travelers cheques; 186 and accepting numerous bulk cash shipments transported by armored car from the CDCs. 187 The filings report that, over a three-year period, the wire activity exceeded $374 billion and the bulk cash shipments exceeded $4.7 billion, far exceeding expected volumes. 188 Wachovia Bank also processed $20 million in See Dec. 2005 "U.S. Money Laundering Threat Assessment," issued by the Money Laundering Threat Assessment Working Group, which included the U.S. Departments of Treasury, Justice, and Homeland Security, Federal Reserve, and Postal Service. 180 "Guidance to Financial Institutions on the Repatriation of Currency Smuggled into Mexico from the United States," FinCEN Advisory No. FIN-2006-A003 (4/28/2006), at 1 . http://www.fincen.gov/statutes_regs/guidance/pdf/advis04282006.pdf. 181 Id. at 1-2. 182 Id. at 2. 183 See, e.g., "Wachovia Is Under Scrutiny in Latin Drug-Money Probe," Wall Street Journal , Evan Perez, Glenn Simpson (4/26/2008)(describing AML cases involving not only Wachovia Bank, but also American Express International Bank, which forfeited $55 million as part of a 2007 Federal deferred prosecution agreement, and Union Bank of California, which forfeited $21.6 million as part of a 2007 Federal deferred prosecution agreement, both of which were also charged with inadequate AML programs and suspected of being used by Mexican drug cartels to launder funds). 184 See United States v. Wachovia Bank N.A. , Case No. 10-20165-CR-Lenard (USDC SDFL), Deferred Prosecution Agreement (3/16/2010) and Information (3/12/2010). 185 See id., Factual Statement, Exhibit A to Deferred Prosecution Agreement (3/16/2010), at fflf 20, 24(1). 186 Id. at Tit 22, 24(2), 35. 187 Id. at H 21, 24(3). 188 Id. at If 23. Case l:12-cv-04269-JBW-RML Document 36-3 Filed 10/25/12 Page 47 of 339 PagelD #: 1386 42 sequentially numbered travelers cheques, the majority of which contained illegible names and 1 89 unusual markings. The deferred prosecution agreement and supporting factual statement charged Wachovia Bank with willfully failing to maintain an effective AML program, 190 detailing numerous AML deficiencies including a failure to conduct due diligence on high risk clients; a failure to monitor wire transfers, pouch activities, and bulk cash shipments; and a failure to report suspicious activity to law enforcement. 191 To avoid prosecution, Wachovia Bank acknowledged responsibility for its conduct, paid $160 million in criminal and civil fines, and agreed to undertake significant AML reforms. 92 The Wachovia case received widespread 193 media attention, providing further notice of the money laundering dangers in Mexico. (2) HSBC Assessment of Risk in Mexico Despite the overwhelming information available about substantial money laundering risks in Mexico, from 2002 until 2009, HBUS gave Mexico its lowest risk rating for AML purposes. 194 As a consequence, under HSBC Group policy, clients from Mexico were not subjected to enhanced monitoring by HBUS, unless they were also designated a Special Category Client (SCC), a relatively rare designation that indicates a client poses high AML risks. Had Mexico carried one of the two highest risk ratings, all Mexican clients at HBUS would have been subjected to enhanced due diligence and account monitoring. Instead, HBUS failed to conduct AML monitoring of most Mexican client account and wire transfer activity involving substantial funds. Risk Rating Process. Until recently, HSBC Group and HBUS issued AML country risk assessments using four categories of increasing risk, "standard," "medium," "cautionary," and "high." HSBC Group created a chart listing its country risk assessments, sent the chart to its affiliates characterizing its assessments as recommendations, and then allowed each HSBC affiliate to make its own assessment decisions. 195 At HBUS, the country risk assessments were compiled every six months by an AML compliance officer who gathered information from a number of sources, assigned numerical scores to each source, and then compiled aggregate scores for over 200 countries. 196 Those scores were then supposedly used to assign risk ratings. In fact, however, countries receiving similar scores often received different risk ratings. Those differences were attributable, in part, to an "HBUS discretion" factor which was listed as an official factor in the 1>