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Scott and Jean Webster -v- Wells Fargo Bank, et al Docket No: 08 CIV 10145 before the Honorable Judge Preska |
THE PARITES
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----- PLAINTIFFS -----
11. Plaintiff Scott E. Webster is a citizen of the State or
Commonwealth of Virginia, residing at 204 Charlotte Drive, County of
Carroll, Virginia, 24325, (276) 728-5006, and is the husband of
co-Plaintiff Jean Allen Webster, and is appearing at this time pro
se (hereinafter "SCOTT WEBSTER"), is over 65 years of age and a
senior citizen.
12. Plaintiff Jean Allen Webster is the wife of co-Plaintiff
Scott E. Webster, is a citizen of the State or Commonwealth of
Virginia, residing at 204 Charlotte Drive, County of Carroll,
Virginia, 24325, (276) 728-5006, and is appearing at this time pro
se (hereinafter "SCOTT WEBSTER") and jointly as (hereinafter
"PLAINTIFFS")
----- DEFENDANTS -----
13. Defendant Wells Fargo Bank, NA, is a national association
banking institution organized under the laws of the United States of
America, with a home office at 464 California Street, San Francisco,
CA 94104, and at all times discussed herein, acted by and through
the employees referenced, several being co-defendants herein. Wells
Fargo Bank N.A., d/b/a Wells Fargo Home Mortgage which is wholly
owned by Wells Fargo Bank, N.A. is the listed lender in this
underlying action with offices located in the State of New York and
at times also uses an address at 179 Sully's Trail, Suite 100,
Pittsford, NY 12534, and before the New York State Supreme Court
actions as 3467 Stateview Boulevard, Ft. Mill SC 29715, (hereinafter
"WELLS FARGO" collectively). The U.S. Code, 28 U.S.C. Section
1391(c) provides that a corporation shall be deemed to reside in any
judicial district in which it is subjected to personal jurisdiction
at the time of the action is commenced.
14. Defendant Wells Fargo Home Mortgage is wholly owned by
Wells Fargo Bank, N.A. and is successor by merger to to Wells Fargo
Home Mortgage Inc., with a listed address of 3467 Stateview
Boulevard, Ft. Mill SC 29715 and for the purposes of this action
treated as one entity (hereinafter also "WELLS FARGO"
collectively).
15. Defendant Richard M. Kovacevich, is the CEO of Defendant
WELLS FARGO, with a headquarters address of 420 Montgomery St., San
Francisco, CA 94101, hereinafter "KOVACEVICH".
16. Defendant Sean Nix, is an agent and employed by Defendant
WELLS FARGO as a Vice President Loan Documentation (hereinafter
"SEAN NIX"), and upon information and belief, uses the same address
as WELLS FARGO.
17. Defendant Marcia H. Francis, Home Mortgage Consultant,
is/was an agent and or an employee of Defendant WELLS FARGO and is a
mortgage broker for them, and has work address of Wells Fargo Home
Mortgage, 1399 route 52, Suite 202, Fishkill, NY 12524, (845)
440-2337 (hereinafter "AGENT FRANCIS").
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18. Defendant Dominick Penzetta was, and is an agent and
attorney hired by Defendant WELLS FARGO for a closing with
PLAINTIFFS, and has an address of 33 Henry Street, PO Box 429,
Beacon, NY 12508, telephone (845) 831-5291, (845) 831-2384 fax,
(hereinafter "PENZETTA").
19. Defendant John Guttridge Esq., assigned referee is located
at 303 South Broadway, Terrytown, NY 10591, telephone (914)
631-6900, (914) 631-6644 fax, (hereinafter "REFEREE") and works
closely with and for Defendants WELLS FARGO and Steven J. Baum, PC.
20. Defendant Steven J. Baum, PC, is said to be the law firm
representing WELLS FARGO in all matters in New York State as well as
in the foreclosure action in the State Supreme Court, Putnam County,
New York, and has an address of 220 Northpointe Parkway suite "G",
Amherst, New York, 14228, (716) 204-2400 (hereinafter "BAUM LAW
FIRM").
21. Defendant Darleen V. Karaszewski, Esq., attorney with the
Steven J. BAUM LAW FIRM and submitted legal papers on behalf of
WELLS FARGO and the BAUM LAW FIRM and uses the same address and
telephone numbers as the BAUM LAW FIRM (hereinafter "KARASZEWSKI").
22. Defendant AFFORDABLE FINANCIAL SERVICES LTD is a mortgage
Broker, located at 6 Winfield Street, Huntington New York 11743, and
conducts business at 95 Oser Avenue, Happague, Long Island NY,
11788, (631) 288-8714 (hereinafter "AFFORDABLE").
23. Defendant John Baldwin Jr., lists his title as a Certified
Mortgage Broker and is/was an agent for AFFORDABLE at 95 Oser
Avenue, Happague, Long Island NY, 11788, (631) 288-8714 (hereinafter
"BALDWIN").
24. Defendant River City Abstract LLC is a real estate title
abstract company and represented WELLS FARGO at the closing of
PLAINTIFFS' closings and is located at Riverside Office Park, 2645
South Road suite 4, Poughkeepsie, New York, 12601 (845) 463-4797,
fax (845) 463-4765 (hereinafter "RIVERCITY ABSTRACT").
25. John and Jane Doe are individual parties, if any, who may
have helped and abetted any of the above defendants, individually,
or in concert, to hurt Plaintiffs financially, or by violation of
their Constitional Rights of Due Process and/or Equal Protection
Under the Law.
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Scott E. Webster 276-728-5006 Virginia Number Email info@the-cri.com and include for the subnject matter RE: Wells Fargo |