[APPROVED AND STAMPED BY THE COURT ON MARCH 16, 2009]

                                          Before the Honorable
UNITED STATES DISTRICT COURT                   Judge Preska
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------------------+
SCOTT E. WEBSTER, and JEAN ALLEN WEBSTER,      |  JURY TRIAL DEMANDED
                                               |  ===================
                   Plaintiffs, pro se          |
             vs.                               |          - CV -
                                               |
WELLS FARGO BANK, N.A., SUCCESSOR BY           |
 MERGER TO WELLS FARGO HOME MORTGAGE, INC.     |      CASE NUMBER:
 3467 Stateview Boulevard, Ft. Mill SC 29715   |
 and d/b/a WELLS FARGO HOME MORTGAGE,          |
RICHARD M. KOVACEVICH AS CEO WELLS FARGO       |      08 CIV 10145
BANK, N.A., SEAN NIX, DOMINICK PENZETTA,       |
MARCIA FRANCIS, STEVEN J. BAUM PC, DARLEEN V.  |
KARASZEWSKI, AFFORDABLE FINANCIAL SERVICES,    |
JOHN BALDWIN, RIVER CITY ABSTRACT,             |        AMENDED
JOHN GUTTRIDGE ESQ., John Doe and Jane Doe     |
being persons unknown, if any, who abbetted    |        VERIFIED
individually, or in concert with any of the    |
above named defendants in the acts being       |        COMPLAINT
complained of in this action, as               |
                  Defendants.                  |
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TO THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

    Upon this Verified Civil Complaint of the Plaintiffs Scott E.
Webster and Jean Allen Webster, shows and alleges as follows:


                        JURISDICTION
                        ------------

  --- Citizenship Diversification / 28 U.S.C. Section 1332 ---

    1.  That the Federal Court of the Southern Disctict of New York
has Jurisdiction as Plaintiffs bring this combined action under
complete Citizenship Diversication, Federal Questions of Law, civil
rights violations of due process and the equal protection statutes
of the U.S.  Constitution, and that the amount being sued for is
greater than the $75,000.00 minimum requirement to bring this
action, and that Plaintiffs further state and show as follows:

                     --- PLAINTIFFS ---

    2.  Plaintiff Scott E. Webster is a citizen of the State of the
Commonwealth of Virginia, is sixty seven (67) years of age and is a
senior citizen.

    3.  Plaintiff Jean Allen Webster is a citizen of the State of
the Commonwealth of Virginia.

                     --- DEFENDANTS ---

    4.  Defendant Wells Fargo Bank, NA, has a location in the State
of New York where the actions complained of took place, and lists
before the New York State Supreme Court actions, addresses of Fort
Mill, South Carolina and Des Moines, Iowa.


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H



    5. All the other Defendants either reside or work in the State
of New York, and the actions complained about occurred within New
York State.

                       --- VENUE ---

    6.  This complaint arises from actions by Defendants that took
place in Dutchess and Putnam Counties regarding the refinancing of
Plaintiffs property located at 18 Fair Street, Village of Cold
Spring, Putnam County, NY 10516, (hereinafter "PROPERTY"), the
filing of various legal papers in the Putnam County Supreme Court,
which is located in the Ninth Judicial District, the venue of the
United States District Court, Southern District of New York.

                --- AMOUNT OF MONEY DAMAGES ---

     7.  Plaintiffs are suing Defendant Wells Fargo Bank, N.A.
successor by merger to Wells Fargo Home Mortgage, Defendants Dominik
Penzetta, Marcia Francis, Steven J. Baum LLC., each for $817,000.00
for their deliberate actions that resulted in the loss of sale of
Plaintiffs Property for all the reasons and facts being put forth,
inter alia, in this Complaint, plus punitive damages, the amount to
be determined by a jury.  The partial amount being sued for is far
greater than the $75,000.00 minimum required to file this action in
Federal Court.

       --- Civil Rights Issues / 28 U.S.C. Section 1331 ---

     8.  In addition to Citizenship Diversation, this action also is
about Civil Rights violations arising under the Constitution, laws,
of 28 U.S.C.  Section 1331 actions, inter alia, where Defendants
Wells Fargo and through their attorney Steven J. Baum LLC, including
several named attorneys in this action, all of whom were and are
operating under the color of Federal and State Laws regarding
lending practices and legal procedures, that the making of false and
misleading representations on Federal Lending Documents and various
Court Papers, thereby sought to deprive Plaintiffs of their
constitutional rights of Due Process and Equal Protection under the
Law through the timing, backdating of documents, and multiple
manipulating of court procedures.

       --- FEDERAL QUESTIONS CASE - 28 U.S. SECTION 1331 ---

    9.  This action is also raises issues of Federal Questions
because it involves the violation of Federal laws regarding legal
forms created by the Federal Government, the deliberate misuse of
required legal forms and/or documents, such as RESPA, TILA, HUD
issued by the Federal Government in order to perpetrate fraud,
deceipt, conspiracy and theft of equity.

    10.  This action also involves issues of violations of the
Federal Banking Laws as Defendants were operating under the color of
Wells Fargo Bank, N.A. a bank charted under Federal Laws, that
involve Predatory lending practices set forth and defined in
guidelines by the Federal Government.




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