United States District Court   //   Southern District of New York
Scott and Jean Webster -v- Wells Fargo Bank, et al
Docket No: 08 CIV 10145 before the Honorable Judge Preska

           *** PARTIAL SUMMARY OF DAMAGES TO PLAINTIFFS ***
             AS A RESULT OF THE DELIBERATE ACTIONS OF THE
                     THE VARIOUS NAMED DEFENDANTS

    245.  PLAINTIFFS have been severely damaged by the deliberate
actions of the various named Defendants, both individually and
collectively for their combined actions, which have harmed
PLAINTIFFS in just some of the following areas:

                         * FINANCIAL *

    A)  CREDIT RATING DAMAGE: went from excellent rating of 764
          to 560 "poor" which,
    B)  Prevented PLAINTIFFS from mortgaging VA property to keep
          the PROPERTY from foreclosure and,
    C)  Prevented PLAINTIFFS later from obtaining any reasonable
          financing on their free and clear Virginia property and
          had to take 11.99% with severe penalties,
    D)  Financial stress by having to pay credit cards, household
          expenses, travel expenses,
    E)  Exposure to potential identity theft both by WELLS FARGO,
          AFFORDABLE and BALDWIN,
    F)  Bad credit rating caused by Defendants foreclosure action
          negatively impacts job applications, insurance rates, etc
          for both PLAINTIFFS and,
    G)  Caused all of PLAINTIFFS' credit cards to greatly increase
            interest rates from their normal average of 12% to 28%
            to 31% which,
    H)  Caused monthly credit card payments to increase to such a
            degree that PLAINTIFFS could not make payments and,
    I)  Caused credit card companies to begin taking legal action,
    J)  Destroyed PLAINTIFFS' credit rating.

                              - 42 -
H


                        * MORTGAGES *

    K)  Converted PLAINTIFFS original mortgage from a 30 year fixed
            rate to an ARM at a much higher rate after two years,
    L)  Forced PLAINTIFFS to get financing on Virginia retirement
            home to avoid bankruptcy.



                     * PERSONAL DAMAGES *

    M)  Extreme stress and anquish,
    N)  Humiliation and embarassment in the community for which
            PLAINTIFFS were well known,
    O)  Almost forced PLAINTIFFS into bankruptcy and financial ruin,
            a situation that PLAINTIFFS may still be forced to
            resort to,
    P)  Having to make many 600 mile 11 hour trips to New York & bac    k,
    Q)  Caused PLAINTIFF Scott Webster to seek medical treatment,
            critical enough that the doctor was concerned
            PLAINTIFF Scott Webster might be having, or heading to
            heart attack,
    R)  Caused extreme anxiety, sleep deprivation, anguish due to
            probable total financial ruin,
    S)  Quality of life affected through diminished finances,
            causing PLAINTIFF Scott Webster to scrounge for wood
            just to heat PROPERTY, when furnace oil ran out,
            to point of seeing breath in the mornings in sleeping
            area, which was the dining room, closing off the rest of
            the almost empty house just to keep warm during winter,
    T)  Caused separation and loss of companionship for two years be    tween
            PLAINTIFFS,
    U)  Caused PLAINTIFFS to have to auction off and sell art,
            jewlery, antique guns, two rare antique cars,
            and other collectables, under very poor time conditions
            at a loss in market value just to keep up with credit ca    rd
            payments and household expenses,
    V)  Prevented PLAINTIFF Scott Webster from being able to seek
            employment for 2 1/2 years, being a pro se litigant
            and having to make frequent trips, file legal papers,
            and do research, was prohibitive to retaining any kind
            of regular employment, which still continues.

                    * DAMAGES TO THE PROPERTY *

    W)  Deterioration of PROPERTY physically for over 2 1/2 years,
    X)  Killed three sales of the PROPERTY costing PLAINTIFFS
            OVER $817,000.00, $785,000.00, $785,000.00,
    Y)  Depreciation of the housing market for any sale of the
            PROPERTY,
    Z)  Costs in holding open house such as signs, ads, flyers,

    AA) Damaged PLAINTIFFS efforts to continue the sale of the
            PROPERTY by filing the lis pendens marking the
            PROPERTY unmarketable, known in the real estate arena
            as "the kiss of death" preventing PLAINTIFFS from being
            able to find a buyer.



                              - 43 -
H


                 * ADDITIONAL DAMAGES AND COSTS *

    AB)  600 mile trips costs for fuel, wear and tear on vehicles,
    AC)  Forced PLAINTIFFS to close their business, the Center for
            Radio Information due to the time and finances needed
            to sustain the litigation,
    AD)  Costs of litigation, copying, reproducing, filing fees,
            travel for research, immense time in defense and paperwo    rk
            mailing, trips to Courthouses, costs of motions,
            costs of Appeals.



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Contact information:
Scott E. Webster
276-728-5006 Virginia Number
Email     info@the-cri.com
and include for the subnject matter
RE: Wells Fargo

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