SUPREME COURT OF THE STATE OF NEW YORK
    APPELLATE DIVISION: SECOND JUDICIAL DEPARTMENT
    ---------------------------------------------+
    WELLS FARGO BANK, N.A. SUCCESSOR BY          |
    MERGER TO WELLS FARGO HOME MORTGAGE, INC.    |
    3476 Stateview Boulevard                     |
    Ft. Mill, SC 29715                           |
                                                 |     NOTICE OF MOTION
                       Plaintiff-Respondent      |
                                                 |
            -against-                            |
    SCOTT E. WEBSTER and JEAN ALLEN WEBSTER      |   Appellate Division
                                                 |      Docket No.:
                 Defendants-Appellants, pro se   |
                                                 |        07-09263
    ---------------------------------------------+ and/or 08-00349

        Upon the annexed affidavit of Scott E. Webster and Jean Allen
    Webster Sworn to January 22, 2008, and the papers annexed thereto,
    let Wells Fargo Bank, N.A. and their Attorneys, at the courthouse
    thereof, located at 45 Monroe Place, Brooklyn, New York, 11201, on
    Friday, the 15th day of February, 2008, at 9:30 o'clock in the
    forenoon of that date or as soon thereafter as counsel may be heard,
    why an order should not be made and entered:

        1.  Barring Respondent Wells Fargo Bank N.A. and their attorneys
    from further submission of papers of any type to the Appellate
    Division due to subject matter jurisdiction by their failure to
    achieve initial standing over Defendants-Appellants;

        2.  Holding Respondent Wells Fargo Bank N.A. and their attorneys
    Steven J. Baum, LLC.  in contempt of court and other sanctions the
    Court deems fair for the submission of a false Notice of Entry
    "dated December 14, 2007";

        3.  Holding Respondent Wells Fargo Bank N.A. in contempt of
    court and sanctions for their concealing and back-dating documents
    forwarded to Respondent attorneys and used in the litigation
    against Defendants-Appellants;

        4.  Holding Respondent attorney Czora in contempt and sanctions
    for the submission of her sworn Affidavit Notice of Entry "dated
    December 14, 2007" which was false;

        5.  Holding Respondent attorney Susan M. Silberman, Esq. for the
    obvious complicity in the submission of her sworn Affidavit Notice
    of Entry "dated December 14, 2007" which was false;

        6.  Holding Respondent attorney Darleen V.  Karaszewski, Esq.
    for the preparation and submission of Respondents' Affirmation
    in Opposition dated December 20, 2007 which was based upon the
    submission to the court of the altered dates of the Notice of
    Entry to gain and support a "legal" position against Appellants;

        7.  Holding Pillar Processing, LLC in contempt of court and
    other sanctions this Court deems fair and reasonable, as being the
    "service provider to Steven J.  Baum P.C" and responsible for the
    misleading dates committed by its employees and agents;



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        8.  Holding attorney, identified herein as Jane Doe
    representing Respondent Baum Law Firm, be held in comtempt of court
    and any other sanctions the Court deems fair and reasonable for
    misleading Chief Clerk James Pelzer and Appellant Scott Webster with
    assurances that Respondents would not take further action until
    Appellants Order to Show Cause was decided, and for which reliance
    caused Mr.  Pelzer and Appellant Scott Webster to voluntarily cross
    out the TRO portion of the Order to Show Cause;

        9.  Holding any of the above parties in contempt of court and
    any other sanctions for the continued litigation and

        10.  And any other relief the Court deem fair and reasonable.

        Pursuant to CPLR 2214(b), answering affidavits, if any, are
    required to be served upon the undersigned at least seven (7) days
    before the return date of this motion.


    Dated: Commonwealth of Virginia
           County of Carroll
           January 22, 2007


                                              ________________________________
                                              Scott E. Webster
                                              Defendant-Appellant pro se
                                              18 Fair Street
                                              Cold Spring, New York 10516
                                              204 Charlotte Drive
                                              Dugspur, VA 24325
                                              (276) 728-5006
                                              (845) 265-3413
                                              (845) 265-2715 fax

                                              ______________________
                                              Jean Allen Webster
                                              Defendant-Appellant pro se
                                              18 Fair Street
                                              204 Charlotte Drive
                                              Dugspur, VA 24325
                                              (276) 728-5006


    TO: Steven J. Baum
    220 Northpointe Pkwy, Ste. G
    Amherst, NY 14228
    (716) 204-2400











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