182.  The above bald face statement "... that none of the
Defendants had served any answer to said Complaint..." is a total
fabrication and outright lie!  PLAINTIFFS had served a 63 paragraph
answer with exhibits, eight affirmative defenses, and two
counterclaims, and had done so in a legally and timely manner, even
allowing for the failure to include the LIS PENDENS and the
shielding of the CONSOLIDATED MORTGAGE which stated that it
superceded all other mortgages and notes.  PLAINTIFFS answer is part
of the official record in the Putnam County Courthouse.

    183.  Upon information and belief, the real reason for the
completely false statement above is an attempt to thwart the appeal
process that PLAINTIFFS have filed with the Appellate Division,
Second Judicial Department, on December 26, 2007, as PLAINTIFFS
found when they filed a second Motion for a Stay to stop WELLS
FARGO, the BAUM LAW FIRM, and GUTTRIDGE, the referee from selling at
forced auction of PLAITNIFFS' the PROPERTY, as an associate Clerk of
the Appellate Division at first refused to take PLAINTIFFS Order to
Show Cause and stated that PLAINTIFFS had no right to an appeal
because no answer to the Complaint was submitted.

    184.  This issue had apparently had been brought to the Clerk's
attention by the lawyer representing the BAUM LAW FIRM the morning
of the submission who showed up to oppose PLAINTIFFS Order to Show
Cause requesting the stay, as opposing parties must be notified if
they wish to challenge the signing of the motion.

    185.  PLAINTIFF Scott Webster corrected this erroneous
information and the Order was submitted to a sitting judge who
signed it.  PLAINTIFFS, however were denied the motion, not on any
merits, but just a denial.  Given that the issue of PLAINTIFFS
having submitted "no answer" to the complaint, was no doubt the
reason for the denial ?? as the Justices first look at the Notice of
Appeal, and then the decision and or order being appealed from.
They would have seen WELLS FARGO'S sworn statement on the JUDGEMENT
OF FORECLOSURE AND SALE, that clearly stated that PLAINTIFFS had
never submitted an answer, and that the entire matter being appealed
was in fact, an "uncontested foreclosure".  Naturally, they would
have dismissed PLAINTIFFS' Order for a Stay for that reason alone.
This was clearly another example of denying PLAINTIFFS of due
process of law, as a timely notice of appeal, and the process, is a
right, not requiring leave.

    186.  Upon information and belief, that the BAUM LAW FIRM by the
above stated false claim that PLAINTIFFS had not filed an answer to
the Complaint is violation of PLAINTIFFS right of due process, as
they have intentionally raised a serious question which could not be
cleared up with a telephone call to the Appellate Division, as to
whether PLAINTIFFS will be allowed to finishing perfecting their
appeal.  The clerks are not sure, which will force PLAINTIFFS to
seek a clarification before compiling 13 copies of records, filing
fees, and endless time finishing the brief.

    187.  What ever the outcome, the BAUM LAW FIRM'S intent was
certainly clear, to violate PLAINTIFFS' right of due process, and
prevent PLAINTIFFS from appealing both the Amended Decision and
Order, the JUDGEMENT FOR FORECLOSURE AND SALE, and even the ORIGINAL
DECISION AND ORDER which was totally based upon the ORIGINAL
MORTGAGE which, as stated above was paid and satisfied.


                              - 33 -
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   --- WELLS FARGO'S INTENT WAS TO TAKE APPELLANTS EQUITY ---

    188.  PLAINTIFFS had in their Supreme Court Affidavits raised
the serious issue of WELLS FARGO and the BAUM LAW FIRM'S submission
of three very important undated and unidentified pages of documents
as their exhibit "G" as and for proof of a title search of the
County Records to support of their Complaint and Motion for Summary
Judgement, however these pages contained no name, address, fax or
telephone number or other supporting information.

    189.  This was a critical issue to PLAINTIFFS because in
preparing their defense, the first page is totally false and
incorrect where it is clearly titled "MORTGAGES" and where the first
line states "(A) MORTGAGE TO BE FORECLOSED" ...  $162,000.00.  This
again is the ORIGINAL MORTGAGE that was paid off and satified as
shown on the SATISFACTION OF MORTGAGE, and therefore this exhibit
"G" is not only misleading, prejudicial, it was also used the basis
for the filing of their LIS PENDENS.

    190.  PLAINTIFFS complained to the Supreme Court in their
Affidavits that these three undated, unsigned non official pages
were merely heresay "notes" which could have been produced by
anyone, and therefore did not rise to the level for probate.

    191.  The source of these three "rogue" pages recently came to
light however for the final submission by WELLS FARGO and the BAUM
LAW FIRM to the Court in support for their THE JUDGEMENT OF
FORECLOSURE AND SALE which was signed by JSC O'ROURKE on November
30, 2007.  For the first time the source of those pages was the
attached cover page from Prime Title Search, LLC., bearing the title
of "MORTGAGE FORECLOSURE CERTIFICATE ...  CERTIFIES TO: Steven J.
Baum, P.C." and further states, "Certified as of October 1, 2006 at
9:00 A.M." by Prime Title Search, LLC.

    192.  Up until that sumbission, WELLS FARGO, the BAUM LAW FIRM,
and JSC O'ROURKE had ignored PLAINTIFFS affidavits and papers that
challenged those three accompanying pages they had put forth in
support of the Complaint and their Motions.  The failure to include
the identifying cover page is proof that they tried to shield that
information from PLAINTIFFS and the Court.

    193.  Most important is the fact that it clearly states
"Certified as of October 1, 2006 at 9:00 A.M." by Prime Title
Search, LLC.  This is clear and undeniable proof that WELLS FARGO
never intended to work with PLAINTIFFS in any way, that WELLS FARGO
was interested only in foreclosing on PLAINTIFFS' PROPERTY to help
themselves to the large equity PLAINTIFFS had earned in the twenty
four years they had owned and improved the PROPERTY.

    194.  As stated back in paragraph 117, PLAINTIFFS, believing
that a close working relationship existed, sent AGENT FRANCIS, the
broker agent/employee for WELLS FARGO, a personal letter on
September 12, 2006, detailing the possible potential problems that
they could face.  One of the suggestions she made was to send to
WELLS FARGO'S loss mitigation department a HARDSHIP LETTER which
PLAINTIFFS did on October 24, 2006, which was at least 24 days after
the above Certified cover page of October 1, 2006, from Prime Title
Search regarding the certification for foreclosure.


                              - 34 -
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    195.  That by the time Prime Time prepared and dated their
certification for foreclosure letter dated October 1, 2006, on a
Monday, they had to do a "title search" and prepare the the letter
and the three pages that the BAUM LAW FIRM submitted in Court
Affidavits, actions that had to have been done during the week
before.

    196.  PLAINTIFFS by the time of sending their letter to AGENT
FRANCIS were but a month behind on their mortgage payments, and
therefore WELLS FARGO would, at best only have knowledge of a late
payment, and would have no practical or legal reason to notify the
BAUM LAW FIRM to begin foreclosure proceedings as they, at that
time, would have no way of knowing, for at least another month, by
PLAINTIFFS HARDSHIP LETTER of October 24, 2006, unless of course
AGENT FRANCIS notified them.

    197.  Again, as previously stated, at the time of the filing of
the foreclosure action, PLAINTIFFS were behind less then $25,000
owed on back mortgage payments and that WELLS FARGFO was protected
with at least a $350,000 pure equity balance on the PROPERTY.

    198.  That upon information and belief, that belief being that
obviously that AGENT FRANCIS had made direct contact with the BAUM
LAW FIRM directly and the foreclosure process actually began more
than a month prior to PLAINTIFFS notifying WELLS FARGO with the
HARDSHIP LETTER, and that, at the very least, conspired to steal the
very large earned equity from PLAINTIFFS, and the Defendants did
every thing they could to prevent the sale by PLAINTIFFS of their
PROPERTY.

    199.  It was therefore, not in the interest of either AGENT
FRANCIS, the BAUM LAW FIRM, or WELLS FARGO to allow PLAINTIFFS to
complete any sale on the PROPERTY, and the hastly filed LIS PENDENS
was, as is commonly known in the real estate market, the "kiss of
death" that would serve the Defendants well in preventing any
reasonable offers, or closings on PLAINTIFFS PROPERTY.

    200.  As stated before, PLAINTIFFS, trying to work with WELLS
FARGO through AGENT FRANCIS, kept her notified of their entire
financial situation including all assets, how they were proceeding
with the attempts to sell the PROPERTY and that PLAINTIFFS were
having very good responses from the FSBO open houses, and unknown to
PLAINTIFFS at that time, foolishly steered all their potential
buyers to her.

    201.  That given that AGEMT FRAMCIS initially triggered and
prompted the BAUM LAW FIRM into starting the foreclosure process
PLAINTIFFS allege that a conspiracy existed between them which
necessitated the cooperation of other employees who joined,
knowingly or unknowingly, in breaking the guidelines, rules, and
laws, designed to protect borrowers from predatary lending
practices, and the crime of theft of equity.

    202.  As further proof of the actions by AGENT FRANCIS and the
BAUM LAW FIRM, in a letter dated November 22, 2006 from Wells Fargo
Home Mortgage to PLAINTIFFS carried the obviously false statement
that read:  "The above loan file has been referred to our attorney
with instructions to begin foreclosure proceedings."


                              - 35 -
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This of course is a total lie as the Prime Time cover letter which
states "MORTGAGE FORECLOSURE CERTIFICATE ...  CERTIFIES TO: Steven
J. Baum, mortgages..." had been started almost two months prior.

    203.  The fact that this Certification was issued two and a half
months before WELLS FARGO and the BAUM LAW FIRM initiated the
foreclosure action against PLAINTIFFS, is prime facie proof, that
WELLS FARGO never had any intention of allowing PLAINTIFFS to sell
their PROPERTY, and the underlying reason they refused to work to
help with the selling of the PROPERTY on behalf of their "client".

        "...as your loan servicer, we will be attempting to
        collect a debt..."
        December 26, 2006

        January 22, 2007 Wells Fargo Home Mortgage, Fort Mill, SC
        "There may be other alternatives that will assist you
        but are contingent upon agency investor approval."

    204.  WELLS FARGO, in spite of their repeated assurances by
telephone calls with their agents that "we don't want your house"
"don't worry, they won't foreclose" that the Prime Time cover letter
shows WELLS FARGO never intended to work with PLAINTIFFS, and
delayed assigning someone to work with PLAINTIFFS for over
sixty-eight (68) days until they could file the Summons and
Complaint on December 21, 2006, just so they could force PLAINTIFFS
into foreclosure, again for the large equity PLAINTIFFS enjoyed with
their PROPERTY.

    205.  Upon information and belief, that belief being the above
stated actions, especially regarding the Prime Time Certification
Letter, that clearly shows that WELLS FARGO and the BAUM LAW FIRM,
are part and parcel, jointly engaged in a scheme to defraud and
deceive PLAINTIFFS with the full intention of stealing the equity in
the PROPERTY, and that these kind of activities and intentions are
self-evident of a criminal enterprise.

    206.  That the other named Defendants herein, have shown a
pattern and also acted as part and parcel of that kind of conspiracy
to defraud borrowers, in particular seniors who have built up large
equities, to take those equities by forcing borrowers into
foreclosures so they can themselves, or acting individually purchase
borrows' properties at a fraction of the fair market value, as they
are attempting with PLAINTIFFS.

    207.  PLAINTIFFS, upon information and belief, that belief being
the circumstantial evidence as supported by the Prime Time cover
letter that the BAUM LAW FIRM had acutally purchased the loan
obligation from WELLS FARGO prior to the October 1, 2006 date.

    208.  Since the Prime Time cover letter was in the hands of the
BAUM LAW FIRM months before the actual filing of the Summons and
Complaint, this constitutes proof of the devious actions taken in
the Supreme Court by them, all of which was initiated from the very
beginning of of the loan application with the intended goal of theft
of equity of PLAINTIFFS' PROPERTY.

    209.  The failure to attach the Prime Time cover letter on the
Affidavit in support of WELLS FARGO'S initial Motion for Summary
Judgement by SEAN NIX as his exhibit "F" but delibertly used only
the three undated title search pages, would have shown support for
PLAINTIFFS assertions that the entire foreclosure action was
contrived from the beginning.

    210.  Never did the BAUM LAW FIRM attempt to contact PLAINTIFFS
to try to resolve the situation and help to protect their "client"
WELLS FARGO'S financial interest, which could have easily been done,
at the first and second "conferences" called by JSC O'ROURKE, or the
two meetings with the lawyer representing the BAUM LAW FIRM at the
Appellate Division.


           --- THE BALDWIN AND AFFORDABLE FACTOR ---

    211.  On or about March 2007, PLAINTIFF Scott Webster received
one of many calls from financial organizations and brokers offering
help to home owners in foreclosure situations, which information was
easily found on the internet foreclosure sites, as PLAINTIFFS'
PROPERTY had been listed, although for the ORIGINAL MORTGAGE that
had been paid and satisfied.

    212. One of these calls was from a John BALDWIN and agent of
AFFORDABLE Financial Services, who claimed on that original call
that he had contacts with lenders who specialized in troubled
properties, and virtually assured PLAINTIFFS that it would not be a
serious problem, but it would be expensive, ten to twelve percent
interest, which PLAINTIFFS realized would be necessary, and seemed
probable to accomplish under those kind of terms.

    213. PLAINTIFFS after checking what limited website information
was available about Affordable Financial Services, and receiving
BALDWIN'S promotional materials and loan application forms, filled
out and signed for the loan application on the Virginia property.

    214.  PLAINTIFFS were now caught in a very serious situation,
created when WELLS FARGO and the BAUM LAW FIRM filed the LIS PENDENS
and posted the foreclosure action that now became listed on the
public County Records, causing PLAINTIFFS' credit report, credit
rating to be destroyed, and virtually preventing PLAINTIFFS from
securing any financing for their Virginia property, again which was
free and clear of any liens or mortgages, that was appraised in
August 2007 for $315,000.00.  Again, the actions of WELLS FARGO and
the BAUM LAW FIRM arbitrarily filing initiating foreclosure at that
time would probably force PLAINTIFFS into a forced sale of the
PROPERTY at a fraction to them.  See below regarding the posting of
the notice of auction.

    215.  WELLS FARGO and the BAUM LAW FIRM being professionals in
the real estate arena, knew full well that their deliberate acts in
initiating the foreclosure and LIS PENDENS would effectively
guarentee them of the ability to get PLAINTIFFS' equity, and
therefore was intended.  The only way to prevent PLAINTIFFS from
securing financing on the Virginia property and prevent foreclosure
was to prevent any financing by PLAINTIFFS.

    216.  BLADWIN kept in close contact with PLAINTIFFS, with
assurances and repeatedly told PLAINTIFFS they had been approved

                              - 37 -
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that this was a tough sell to what was described earlier as a
private person or group, but that the financing would definitely
take place.  PLAINTIFFS according to BALDWIN'S assurances, expected
a closing before July 4, 2007, when PLAINTIFF Scott Webster departed
for Virginia.

    217.  From their initial answer in the Supreme Court to the
foreclosure action PLAINTIFFS mounted not only a vigorus legal
defense, continued to promote and sell the PROPERTY, and even posted
a non public website for the potential lenders that BALDWIN
approached that included many of the legal papers PLAINTIFFS
submitted, but also included letters, links to the extensive website
PLAINTIFFS created to promote the PROPERTY, and a website for the
Virginia property.

    218.  BALDWIN said that the website regarding PLAINTIFFS
position and papers was very helpful to the finance persons he was
dealing with for PLAINTIFFS' financing, and so BALDWIN kept asking
for all the latest legal information.

    219.  However for the next five months, according to BALDWIN,
there was endless problems with the appraisal, countless "mixups"
and other matters, and many phone calls, emails.  BALDWIN also
became very evasive by not returning telephone calls even with
PLAINTIFFS urgent messages on his voice mail.  On several occasions
when PLAINTIFFS were told he was not in, or receiving the voice
mail, PLAINTIFFS had friends call who immidiately were put on with
him.

    220.  BALDWIN knew about the serious situation PLAINTIFFS were
in, and with the credit card companies threatening legal action and
turning the accounts over to collection agencies that despite
PLAINTIFFS urging BALDWIN to try to speed things up, BALDWIN
assurred PLAINTIFFS that the financing had been approved, and even
sent PLAINTIFFS two different commitment letters from lenders.
BALDWIN even told one collection agency that there would be a
closing within two days, definitely within two weeks.

    221.  PLAINTIFFS had no other choice but to try to work with
BALDWIN, and were even checking into bankruptcy because of the
credit cards, and BALDWIN knew that, and even suggested that
bankruptcy might be a good alternative.

    222.  Perhaps the most devious action by BALDWIN was a scheduled
"walkthrough" needed by the lender prior to closing and after he
sent commitment letter, for which he said had been scheduled and
then rescheduled several times.  PLAINTIFFS anxiously waited and
virtually prayed for a closing date.

    223. BALDWIN told PLAINTIFFS that they were his highest priority
that on several occasions that he would be workking on the financing
over the weekend, and other statements to string PLAINTIFFS along,
especially to seek other financing.

    224.  Finally, after PLAINTIFFS sent BALDWIN an email where he
angrily wrote that he was very busy, give him some time, and in
effect to leave him alone, PLAINTIFFS contacted one of the lenders
listed without a phone number on one of BALDWIN'S "commitment
letters", and were shocked to find out that not only had they not

                              - 38 -
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made a commitment for PLAINTIFFS, that BALDWIN had merely submitted
a general standard application form back on September 19, 2007, but
had not followed up on any other of the papers PLAINTIFFS had given
him necessary for the approval of the mortgage.

    225.  BALDWIN'S delays were all a charade, going so far as to
commit fraud by sending PLAINTIFFS "commitment letters", telling a
credit card company of a definite closing within two days,
constantly reassuring PLAINTIFFS that they had their loan
application approved, making false statements regarding the
appraisal, generally leading PLAINTIFFS to believe that a closing
was going to happen.

    226.  PLAINTIFFS, upon information and belief, that belief being
the actions of BALDWIN, that he had been in contact with the BAUM
LAW FIRM and conspired with them to keep PLAINTIFFS from securing
any kind of financing from their Virgina property that would enable
them to continue the necessary litigation by way of filing fees,
travel costs, copying costs, or funds to keep the PROPERTY heated
during the upcoming winter, let alone bankruptcy from the credit
card companies which he knew about.  The litigation which PLAINTIFFS
kept BALDWIN informed about included the filing of two appeals from
the Supreme Court, two applications to the Appellate Division, but
most important the threat to the herein named Defendants of this
impending Federal Law Suit.

    227.  PLAINTIFFS, upon information and belief, that belief being
the actions of BALDWIN, that he outright repeatedly lied to keep
PLAINTIFFS from attempting to seek other financing, to gather
critical information and plans that he fed back to the BAUM LAW
FIRM, and as a result acted in concert with some of the other named
Defendants to force PLAINTIFFS into foreclosure, which is supported
by the fact that since he never had any intentions of securing the
financing would be willing to give up a commission which would
amount to $4,500.00.

    228.  PLAINTIFFS, upon information and belief, that belief being
the actions of BALDWIN, that he was part and parcel of a conspiracy
that acted as a criminal conspiracy as he violated the lending laws
of the State of New York and Federal Laws, all for private gain, all
with the intentions of damaging PLAINTIFFS.

                    --- COURT REFEREE ---
           --- ADVERTISING PLAINTIFFS PROPERTY ---

    229.  In the BAUM LAW FIRM'S prepared JUDGEMENT FOR FORECLOSURE
AND SALE signed by JSC O'ROURKE, contained the following order:

       "...that the said Referee give public notice of the
       time and place of such sale according to law and the
       practice of this Court, in an official publication,
       to wit: THE PUTNAM COUNTY PRESS; ..."

    230.  This is a completely unrecognizable and virtually unknown
paper in Putnam County serving the small community of Mahopac only,
that has very limited circluation.  The Putnam County Press is not
registered with the NYS Sectrary of State, and neither is Mondo
Code, LLC, or Mondo Press, who purport to be the owners and/or
contact persons.

                              - 39 -
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    231.  PLAINTIFFS assert that it is hard to believe that a
sitting Supreme Court Judge in this smallest of New York State
counties, a Judge who was the Westchester County Executive, and upon
information, the former Mayor of Yonkers who was a lawyer active in
the real estate theater, would know just how small this and
insignificent this wholly non serious publication represents.

    232.  Likewise the Lower Court's selection of the REFEREE, who
would certainly know the shortcommings of this paper, as he is
located in Tarrytown within a few miles from Mahopac.  And since the
BAUM LAW FIRMS is located several hundred miles from Mahopac, in
Buffalo, New York, that when they prepared and submitted the
JUDGEMENT FOR FORECLOSURE AND SALE papers submitted to the Court,
how did they come to know this insignificant paper, or was it
carefully worked out from other foreclosing actions.

    233.  The selection of that paper for the auction only points up
an extremely serious situation where home owners would never receive
anywhere near a fair price, nor would WELLS FARGO, unless as stated
above, this was the real intent, to steal PLAINTIFFS' equity.

    234.  This practice, approved by JSC O'ROURKE is not only
malicious and punitive, but strongly suggests a collusion amongst
the various actors in this lending process of which PLAINTIFFS
became victims from the very beginning of the initial financing,
where the intent initially was fraudulent in an attempt to prevent
Appellants from selling the property and force us into a situation
where Respondents whould help themselves to PLAINTIFFS' equity.


                 --- SUPREME COURT ACTIONS ---

    235.  JSC O'ROURKE as the only sitting Supreme Court Judge
enjoys the privelege that every attorney, plaintiff or defendant
both criminal and civil will come before him, and he therefore it is
most critical that he must maintain the appearance impartiality.
PLAINTIFFS have maintained and have yet to receive any satisfactory
answer to their inquiry for New York State Law that requires county
and Supreme Court judges to be selected at random, which PLAINTIFFS
believe to be a deniel of their rights of due process.

    236.  PLAINTIFFS allege upon information and belief, that belief
being the actions of JSC O'ROURKE had taken against PLAINTIFFS
repeatedly in the foreclosure action, especially regarding his
immediate signing of the BAUM LAW FIRM'S illegal motion with the
carefully worded AMENDED DECISION AND ORDER faxed to court chambers
which PLAINTIFFS described in paragraph 147 above, indicate that
that the BAUM LAW FIRM has a very close relationship with his Honor
and that an obvious ex-parte relation ship existed in order to allow
the BAUM LAW FIRM to evade the rules of the CPLR requiring filing of
a proper motion CPLR 2221 for leave to reargue, and file that motion
only after paying the filing fee CPLR 8020.

    237.  Upon information and belief, that the actions of JSC
O'ROURKE was the prior mayor or councilman of Yonkers, New York,
and that he had a law practice in the real estate arena, and that
given the some twenty nine years that the BAUM LAW FIRM has been
operating, that JSC O'ROURKE must have done, and casual information
indicated that he did work for them in and around that time.

                              - 40 -
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     --- BAIT AND SWITCH / PENZETTA AND RIVERCITY ABSTRACT ---

    238.  The above noted SATISFACTION OF MORTGAGE document was a
complete fraud, intended to induce PLAINTIFFS into continuing with
WELLS FARGO'S last minute bait and switch tactic with the mortgage
applications, involving forcing PLAINTIFFS into the equity credit
line, which PLAINTIFFS would not have continued with before
insisting WELLS FARGO file the SATISFACTION OF MORTGAGE with the
County.

    239.  Upon information and belief, WELLS FARGO through agent
PENZETTA never intended to file the SATISFACTION OF MORTGAGE in
order to prevent any closing by PLAINTIFFS on the PROPERTY to force
PLAINTIFFS eventually into a foreclosure action where WELLS FARGO,
or affiliates of WELLS FARGO with insider knowledge, would be able
to purchase the PROPERTY at least 60% below what they knew as fair
market value.

    240.  The above intent not to file the SATISFACTION OF MORTGAGE
by the recent letter from PENZETTA to PLAINTIFFS dated August 13,
2007 in response to PLAINTIFFS prior written demand of what had
actually happened at and after the closing, he incredibly stated the
following which should be of major concern to any borrower entering
into any arrangement with a lender:

        "However, it is very common for the lenders who held
        the mortgages (not Wells Fargo) to not send a satisfaction
        for recording or to send one with an error on it.  As
        an attorney representing sellers in real estate closings,
        I see this arise in title reports on a regular basis.
        This is resolved by notifying the new title company of the
        name, phone number, and title number for the title
        company who insured the refinance.  The new title company
        sends the prior title compnay a request for something called
        an "indemnification letter."  The prior title company
        sends the indemnification letter to the new title
        company promising to indemnify them for any loss that might
        be incurred by them insuring the sale transaction.
        The prior title company then generally follows up to
        see that the satisfactions are filed, but the closing
        is not delayed."

    241.  That frightening admission regarding lenders, that by its
very nature, any lender could hold up any sale through the title
companies, since the lender would have to file the satisfaction of
mortgage in order to place it on the County records.  This admission
gives a strong reason why PLAINTIFFS SATISFACTION OF MORTGAGE on the
ORIGINAL MORTGAGE that was paid off and satisfied as was held in the
ORIGINAL DECISION AND ORDER.

                    --- THE TITLE COMPANY ---

    242. RIVERCITY ABSTRACT, the title company at closing was
represented by their agent Ellen Juracek, who was in charge of the
payments and the witnessing of PLAINTIFFS signing, as stated before.
RIVERCITY ABSTRACT was responsible for filing all the proper
documents with the Putnam County Clerk's Office.  This included the
filing of the satisfaction of mortgage for the paid off 1995
mortgage (Exhibit 6 and 7) that they failed to do, and for which

                              - 41 -
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PLAINTIFFS have demanded be filed of WELLS FARGO, PENZETTA, the BAUM
LAW FIRM, and RIVERCITY ABSTRACT.  They have failed to correct these
erroneous documents.

    243. RIVERCITY ABSTRACT instead filed Exhibit 2, the $380,346.31
gap mortgage which WELLS FARGO never filed with PLAINTIFFS credit
report (see Exhibit 4.1 & 4.2), but instead filed the "Consolidated
Agreement" along with the attached CONSOLIDATED MORTGAGE.  Both
RIVERCITY ABSTRACT and PENZETTA have claimed the CONSOLIDTED
MORTGAGE to be merely an "exhibit", however as can be seen on
PLAINTIFFS' Credit Report (Exhibit 4.1) Defendant WELLS FARGO filed
it as a legitimate mortgage, knowing full well that it was not
recorded as a mortgage with the tax paid.

    244.  RIVERCITY ABSTRACT and WELLS FARGO having been made aware
of the situation by PLAINTIFFS' demands, but have refused to correct
the situation, further prima facie proof that the intention of
RIVERCITY ABSTRACT, the BAUM LAW FIRM, PENZETTA, WELLS FARGO, and
AGENT FRANCIS intended, ab initio, to prevent PLAINTIFFS from ever
selling their PROPERTY so that they would be able to payoff all
mortgages and have their PROPERTY free and a clear title, instead by
the filing of the duplicate documents clearly shows that PLAINTIFFS
have been charged at least twice on the $522,000.00 through the
failure to file the satisfaction of mortgage on the $162,000.00 and
the incorrect filing of the $380.346.31.




                              - 36 -
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