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DEFENDANT'S SEPARATE STATEMENT OF UNDISPUTED FACTSTITLE TO REAL PROPERTY INVOLVEDINJUNCTIVE RELIEF SOUGHTJURY TRIAL DEMANDED
Defendants, TWILAA. BUTLERf/k/a WOLFAND CHARLTONA. BUTLERJR("Defendant' "Defendant-Intervenor" "Defendants"), submits this separatestatement of undisputed material facts, together with reference to supportingevidence, in support of Defendant's Motion for Sanctions, Declaratory and
Defe nd an ts S ep ara te S ta tem en t O f U nd is pu te d F ac ts
STA TE O F MAIN ECIVIL
TD BANK N.A. fjkja FIRSTM AS SACHU SET TS BA NK N.A.Plaintiff,
v.
TWILA A. BUTLER fjkja WOLFAN DC HAR LTO N A. BU TLE R JR. pro seDefendantandDefendant-Intervenor.
COUNTY OF PENOBSCOTSUPER IOR D IS TR IC T COURT
Case No .: BANSC-RE -2010-187Judge:
INJUNCTIVE RELIEF SOUGHTDEFENDANT'S SEPARATE STATEMENT OF UNDISPUTEDFACTSJURY TRIAL DEMANDED
[Filed concurrently the following: Notice ofMotion, Defendant's Separate Statement ofUndisputed Facts, Motion to Disqualify OpposingCounsel, Defendants Objection to PlaintiffsWitnesses, Affidavits and Exhibits IncorporatedMotion to Strike and Memorandum of Law,Defendant Twila A. Butler f/k/a Wolfs SwornAffidavit of Fact, Defendant's Motion ForCompensation For Time IncorporatedMemorandum of Law, Supporting Exhibits OnDefendant's Objection to Plaintiffs Motion to LiftStay and Motion for Final Judgment IncorporatedMotion for Sanctions, Declaratory and InjunctiveRelief and Memorandum of Law. [Proposed OrderGranting Defendants Motion]Date of Hearing: _Time of Hearing: _
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STA TE O F MA IN ECIVIL
COUNTY OF PENOBSCOTSU PE RIOR D IST RIC T COURT
Injunctive relief against Plaintiffs TD Bank N.A. and Maine State HousingAuthority Et al and in her objection to all of Plaintiffs claims and proofs.
UNDISPUTED FACTS SUPPORTING EVIDENCEOn or about December 04, 2000 TWILA Declaration of Twila A. ButlerA.WOLF a/k/a Butler, executed a f/k/a Wolf and Exhibits (A)"Fixed Rate Mortgage Note" promising and (B)to pay, a certain sum of money. Thisloan was evidenced by a promissorynote ("Note") and secured by a securityinstrument ("Mortgage') encumberingthe property at 44 Patten St. Bangor,Me. 04401 ("the Property"). TheMortgage was recorded in the OfficialCounty Records The Registry of Deeds,County of Penobscot,The Note executed by TWILA A. Butler Declaration of Twila A. Butler/f/k/a WOLF, was never properly and the actual Note in theindorsed to either Plaintiff TD BANK possession of PlaintiffN.A. or MAINE STATE HOUSINGAUTHORITY,TWILA A. BUTLER /f/k/a WOLF AND Declaration of Twila A. ButlerCHARLTONA. BUTLERJR., were neverinformed of any sale, assignment orindorsement, of the Note, from TD BankN.A. the lender to TD BANKN.A.SERVICINGto, at least 3 more truesales, according to the standard PSA,and then to TD BANKN.A.Nor were theproper sales made and recorded by andor for MAINE STATEHOUSINGAUTHORITY. Both are attempting toindicate that they were both directly,from origination, assigned to theirrespective Trust which is, not legal, ifyou want the trust to close, and be legaland not owe a ton oftaxes. For thesecuritization to exist it must conformto the rules without exception on whichthe trust is formed all depends on the
Defendants Separate Statement OfUndisputed Facts
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ST AT E O F MA IN ECIVIL
COUNTY OF PENOBSCOTSUPERIOR DISTRICT COURT
fact that "the function is the form andthe form is the function" insecuritization and the creation oftrusts. Allthis forgery for naught whentaken into account and considerationthat Defendants never made this loan.Plaintiffs lacks standing in this The Note in issue is NotUnlawful action properly orIndorsed at all by Defendant to
Plaintiff. The Note at bar is inthe possession of Plaintiffs andwould be the forgery thatDefendant keeps asking to see.The Trustee/ TDBank N.A.had/ has Declaration ofTwila A.Butlerpossession of the Original Note as pertheir representation on the face of theNotice of Default and are unable, due toits fraudulent nature, to produce it forthis hearing.
DATED:February 28,2012
Twila A.Butler f/k/a Wolf Defendant pro se
Charlton A.Butler Jr. Defendant-Intervenor Pro se
Defendants Separate Statement Of Undisputed Facts
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DEFENDANTSEXHIBIT
A
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DEFENDANTS EXH IB IT A :Since Defendant T Butler was not given a copy of what she signed and was told she was signing and
agreeing to this is the best Defendant T Butler can do.
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DEFENDANTSEXHIBIT
B
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DEFENDANTSEXHIB IT B :S ince Defendant T Butle r was not g iven a copy of what she signed and was to ld she w as sign ing and
agre eing to this is the be st D efe nd ant T B utle r can do.