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Case 2:16-cv-05301-ES-JAD Filed 2/13/18 Page 1 of 18 Page 1 of 18 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY VERONICA A. WILLIAMS, Plaintiff, Pro Se v. LITTON LOAN SERVICING, HSBC BANK USA, N.A.; GOLDMAN SACHS; FREMONT HOME LOAN TRUST 2006-C MORTGAGE- BACKED CERTIFICATES , SERIES 2006-C; OCWEN; STERN & EISENBERG, PC, Ocwen Financial Corporation Defendants Civ. No. 2:16-cv-05301-ES-JAD RESPONSE TO DEFENDANTS’ “INITIAL DISCLOSURES” DOCUMENT SUBMITTED FEB. 6, 2018 FOR PROBLEMS WITH: NJ Case Docket No. F – 000839-13 NJ Case Docket No. ESSX L – 004753-13 NJ Case Docket No. ESSX L – 000081-11 RESPONSE TO DEFENDANTS’ “INITIAL DISCLOSURES” DOCUMENT Defendants’ Deception & Subversion Obviate their Requests This is yet another, unnecessary delay by the defendants. It also imposes undue stress on the Plaintiff by having to respond multiple times to the same issues that lack all plausibility. Since this document does not yet appear on the U.S. District Court of New Jersey (USDCNJ) list of filings for this case, the defendants’ intention may be to consume more of my time and other resources or, to make me reconsider what they plan to do, in hopes that I will give up. I will not give up. I have already shared as much pertinent information that I can think of. Most of the defendants’ requests or assertions have been address in the 3,500+ pages that I have filed or are in the Federal Rules o Civil Procedure. Nonetheless I shall respond and refer to filings that already address issues identified by the defendants in the Feb. 6, 2018 document. In the first sentence of this document, the defendants’ attorney is ignoring one of the basic tenets of law in the U.S. and many countries. That is, the Plaintiff names the defendants. The defendants have no right or authority to redefine themselves. I, as the Plaintiff, am the only one who can name the people and entities who are charged in my complaint. I have reiterated my selection of defendants several times since this attorney was appointed to the case in 2013. Last year, I clarified this explicitly when I filed Document #51 with the U.S. District Court of New Jersey THIS DOCUMENT MAY BE DOWNLOADED AT http://finfix.org/proof/ADDL/Case_2-16-cv-05301_Plaintiff-Response-to-Defendants-2-6-18-DOC_2-12-18.pdf
Transcript
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Case 2:16-cv-05301-ES-JAD Filed 2/13/18 Page 1 of 18

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

VERONICA A. WILLIAMS, Plaintiff, Pro Se

v.

LITTON LOAN SERVICING, HSBC BANK USA, N.A. ; GOLDMAN SACHS; FREMONT HOME LOAN TRUST 2006-C MORTGAGE- BACKED CERTIFICATES , SERIES 2006-C; OCWEN; STERN & EISENBERG, PC, Ocwen Financial Corporation Defendants

Civ. No. 2:16-cv-05301-ES-JAD

RESPONSE TO DEFENDANTS’ “INITIAL DISCLOSURES” DOCUMENT

SUBMITTED FEB. 6, 2018

FOR PROBLEMS WITH: NJ Case Docket No. F – 000839-13 NJ Case Docket No. ESSX L – 004753-13 NJ Case Docket No. ESSX L – 000081-11

RESPONSE TO DEFENDANTS’ “INITIAL DISCLOSURES” DOCUMENT

Defendants’ Deception & Subversion Obviate their Requests

This is yet another, unnecessary delay by the defendants. It also imposes undue stress on the

Plaintiff by having to respond multiple times to the same issues that lack all plausibility. Since this

document does not yet appear on the U.S. District Court of New Jersey (USDCNJ) list of filings for

this case, the defendants’ intention may be to consume more of my time and other resources or, to

make me reconsider what they plan to do, in hopes that I will give up. I will not give up. I have

already shared as much pertinent information that I can think of. Most of the defendants’ requests

or assertions have been address in the 3,500+ pages that I have filed or are in the Federal Rules o

Civil Procedure. Nonetheless I shall respond and refer to filings that already address issues

identified by the defendants in the Feb. 6, 2018 document.

In the first sentence of this document, the defendants’ attorney is ignoring one of the basic

tenets of law in the U.S. and many countries. That is, the Plaintiff names the defendants. The

defendants have no right or authority to redefine themselves. I, as the Plaintiff, am the only one

who can name the people and entities who are charged in my complaint. I have reiterated my

selection of defendants several times since this attorney was appointed to the case in 2013. Last

year, I clarified this explicitly when I filed Document #51 with the U.S. District Court of New Jersey

THIS DOCUMENT MAY BE DOWNLOADED AT http://finfix.org/proof/ADDL/Case_2-16-cv-05301_Plaintiff-Response-to-Defendants-2-6-18-DOC_2-12-18.pdf

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(USDCNJ). In addition to explaining the history and common nomenclature used by people in the

industry when referring to Goldman Sachs, I provided the Goldman Sachs’ unique identifiers

including their CIK code – 0000886982 –, EIN – 13-4019460 –, Ticket Symbol NYSE: GS and web

site http://www.goldmansachs.com. These are respectively assigned by the U.S. Securities and

Exchange Commission, Internal Revenue Service and by Goldman Sachs itself. Owen’s unique

identifiers provided are CIK code – 0000873860 –, EIN – 65-0039856–, Ticket Symbol NYSE: OCN

and web site http://www.ocwen.com/. C:\CriticalFiles\CURRENT_Post2010\Veronica Williams\Legal_Prepaid\Case_LittonLoan\COURT_Federal-Court-Prep\Case_2-16-cv-05301_Objection-to-Injunction-on-5-23-17.docx

PLAINTIFF HAS 47 YEARS EXPERIENCE IN FINANCE, 38 YEARS KNOWLEDGE OF GOLDMAN SACHS While my financial education and experience pre-dates 1971, I first learned of, and began following,

Wall Street and the expanded financial services industry in 1971. It was in 1971, when I began

working at the Economic Research Service of the U.S. Department of Agriculture. I asked one of the

economists why there was so much secrecy and security surrounding the situation reports we

produced. He explained how Wall Street investors, traders and bankers could use our information

for an unfair and illegal advantage. It was my first solid lesson and insight into the securities side of

the financial services industry.

Just 3 years later, the fathers of two of my fellow students worked at Goldman Sachs. After learning

more about securities and the role of Goldman Sachs, I changed my major from physics to

economics. I have studied, created solutions, serviced and followed financial services and securities

firms ever since. I was recruited as a Financial Industry Regulatory Authority (FINRA) Arbitrator in

2009.

WHY PLAINTIFF DELIBERATELY AND INTENTIONALLY NAMED GOLDMAN SACHS AS A DEFENDANT I deliberately and intentionally named Goldman Sachs as a defendant. When the Litton Loan

refinance salesperson told me that they were now owned by Goldman Sachs and their problems

had been resolved, I checked to confirm ownership. If Goldman Sachs did not own Litton Loan, I

would have served Litton Loan with a legal complaint within days of them acquiring my mortgage a

second time. This is explained in earlier filings with the US District Court of New Jersey, the NJ

Courts, the U.S. Securities and Exchange Commission, the U.S. Consumer Finance Protection Bureau,

the U.S. Treasury and the U.S. Dept. of Justice.

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This effort to rename my defendants is just another red herring. Further, by failing to modify or

respond to the Proposed Discovery Plan that is based on the plan proposed by Mr. Barenbaum, the

defendants’ attorneys must have thought they would get an unjustified dismissal rather than

comply with the Order of the Court. This is another indication that we need to proceed to trial as

quickly as possible. The defendants and their attorneys must learn that no one is above the law.

OTHER OBJECTIONS IGNORE THAT DEFENDANTS HAVE HAD 13 YEARS; LAW FIRM HAS HAD 5 YEARS The first sentence of this document states that “defendants have not completed the investigation”

and “have not completed preparation for trial”. I, the Plaintiff, have conducted the vast majority of

the work for this case by myself. The defendants have had large teams of people available to

support their effort. The defendants should be much more prepared than I, the Plaintiff.

I have continually, openly and in good faith communicated with the defendants, and all of the law

firms they have retained to help them succeed in and to disallow legal responsibility for the theft of

my home. I am aware of at least three law firms, including Duane Morris whom HSBC allegedly had

paid very well to protect all defendants. According to their LinkedIn page

(https://www.linkedin.com/company/duane-morris-llp), Duane Morris has 800 attorneys and 1,610

employees. Stern & Eisenberg (120 employees per LinkedIn) did not separate and begin

representing themselves until after I filed my complaint with the USDCNJ. In an earlier USDCNJ

filing, I documented how these two firms “appeared” to be working together against me. Their

“cooperative” actions have been somewhat subdued since that filing.

The defendants should have been ready to proceed to trial no later than December 2014. To be ill

prepared at this time, the defendants either did not read the 3,500+ pages of evidence that I, the

Plaintiff, have submitted to multiple Courts and Federal Agencies; they did not understand or

believe what has been presented; or they just chose to ignore it. Copies of the complete USDCNJ

filing (about 5 pounds) were sent to each defendant as well as their attorney during the fall of 2016.

The packages were too large and heavy to have been ignored. Proof of mailing and receipt of these

packages is available.

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Many of the demands in this letter pose an undue burden to me, the Plaintiff. My responses are

detailed after each paragraph in Attachment I. The document received is in Attachment II. My

response to item 3 – Computation of Damages Claimed, reiterates a trend that these defendants

and their attorney have espoused. I say to them: In God, whose word I praise— in God I trust

and am not afraid. What can mere mortals do to me? Psalm 56:4

In my response to item 4 – Insurance Agreements, I refer to an earlier filing that name of American

Modern Home Insurance Company that one of the defendants engaged to insure my property.

Although this policy may not “be liable to satisfy part of all of a judgment which may be entered”, I

ask the USDCNJ to order that a copy of this policy be provided. There was a payout that may have

violated New Jersey law. This information is included in the USDCNJ filings.

REASONS WHY DEFENDANTS RESISTED PROVIDING DEPOSITIONS I REQUESTED I, the Plaintiff, asked the defendants’ attorney for a copy of the alleged mortgage that he quickly

showed me during my deposition in July 2014. I noticed that it contained pages that I was told had

been destroyed. Since the person who made the “error” was referred by a long-time colleague, I

did not want to make an accusation until I spoke with my colleague and the person who said the

wrong document had been destroyed. The defendants’ attorney never gave me a copy of the

mortgage, the mediation was never scheduled, my attorneys withdrew and, without my knowledge,

my home was foreclosed upon. This all took place in less than 3 months! I did not see the mortgage

until it was released by the State of New Jersey in 2017, 3 years later!

I, the Plaintiff, attended the deposition of Kevin Flanagan by phone. I heard Mr. Flanagan

corroborate my contention that Litton Loan did not acknowledge or record my mortgage payments.

These depositions corroborate information that I have provided in filings with the US District Court

of New Jersey. Each deposition should be entered into evidence after the defendants’ attorneys

provide them as ordered by Judge Dickson.

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IN CONCLUSION The defendants have had ample opportunity to fix their errors since 2005. Rather than act with

integrity, they have produced fraudulent documents, repeatedly broken their word, and engaged in

unscrupulous tactics and actions to steal my home. During this 13 year battle, they have destroyed

my credit, decimated my health and almost put my firm out of business. I am still working hard to

stop the defendants so that I can improve my health and save my firm. This matter qualifies to be

heard in the U.S. District Court of New Jersey. Reasons are detailed in a separate document to be

filed today. I, the Plaintiff, hope and pray that the USDCNJ will grant my constitutional right to

present my case in front of a jury of my peers.

I, the Plaintiff, look forward to my day in Court. The defendants’ continued delays and lack

of cooperation with USDCNJ confirm that I owe it to my fellow New Jersey residents to present my

case in open Court.

Respectfully submitted,

Veronica A. Williams Pro Se Counsel

/s/ Veronica A. Williams Veronica A. Williams [email protected]

February 13, 2018 Phone (202) 486-4565

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ATTACHMENT I

Plaintiff’s Specific Responses to Defendant’s Feb. 9, 2018 Document INITIAL DISCLOSURES PURSUANT TO FED. R. CIV. P. 26(A)(1) OF DEFENDANTS LITTON LOAN

SERVICING, HSBC BANK USA, N.A., FREEMONT HOME LOAN TRUST 2006-C MORTGAGE-BACKED CERTIFICATES, SERIES 2006-C; GOLDMAN SACHS MORTGAGE COMPANY

(INCORRECTLY PLED AS GOLDMAN SACHS); OCWEN LOAN SERVICING LLC (INCORRECTLY PLED AS OCWEN), AND OCWEN FINANCIAL CORPORATION

Submitted by DUANE MORRIS LLP

/s/ Stuart I. Seiden By: Brett L. Messinger

Stuart I. Seiden

PLAINTIFF: The Defendants’ current attorneys from Duane Morris have spent 5 years trying to

subvert and undermine my legal efforts rather than learning the issues of this case. These

actions pose an undue burden to prolong this prolong this case any longer. Goldman Sachs and

Ocwen were intentionally and deliberately named as defendants. The American Modern Home

Insurance Company could be liable; the insurance policy must be presented to the Court.

Details are provided below.

Defendants Litton Loan Servicing, HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage-

Backed Certificates, Series 2006-C; Goldman Sachs Mortgage Company (incorrectly pled as Goldman Sachs);

Ocwen Loan Servicing LLC (incorrectly pled as Ocwen), and Ocwen Financial Corporation (“Defendants”), by and

through their undersigned counsel, Duane Morris LLP, hereby submit the following initial disclosures pursuant to

Federal Rule of Civil Procedure 26(a)(1).

PLAINTIFF: Goldman Sachs and Ocwen were not incorrectly pled. This was clarified in

Document #51 filed with USDCNJ. Additionally:

I provided the Goldman Sachs’ unique identifiers including their CIK code – 0000886982 –, EIN – 13-

4019460 –, Ticket Symbol NYSE: GS and web site http://www.goldmansachs.com. These are

respectively assigned by the U.S. Securities and Exchange Commission, Internal Revenue Service and

by Goldman Sachs itself. Owen’s unique identifiers provided are CIK code – 0000873860 –, EIN – 65-

0039856–, Ticket Symbol NYSE: OCN and web site http://www.ocwen.com/.

Furthermore, based on information that Goldman Sachs and Ocwen filed with the U.S. Securities

and Exchange Commission, they are responsible for Goldman Sachs Mortgage Company and

Ocwen Loan Servicing LLC, respectively. Excerpts from each SEC filing are noted below:

Ocwen Financial Corporation www.ocwen.com owns all outstanding stock of Ocwen Loan

Servicing LLC https://www.ocwencustomers.com and, thus, bears full responsibility for its

actions.

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“Ocwen Financial Corporation (NYSE: OCN) (Ocwen, we, us and our) is a financial services holding company which, through its subsidiaries, originates and services loans. We are headquartered in West Palm Beach, Florida with offices located throughout the United States (U.S.) and in the United States Virgin Islands (USVI) and with operations located in India and the Philippines. Ocwen is a Florida corporation organized in February 1988. Ocwen owns all of the common stock of its primary operating subsidiary, Ocwen Mortgage Servicing,

Inc. (OMS), and directly or indirectly owns all of the outstanding stock of its other primary operating

subsidiaries: Ocwen Loan Servicing, LLC (OLS), Ocwen Financial Solutions Private Limited (OFSPL),

Homeward Residential, Inc. (Homeward), and Liberty Home Equity Solutions, Inc. (Liberty).” SOURCE: 1OK /A submitted to the U.S. Securities and Exchange Corporation, May15, 2017 SEC DOCUMENTS: https://www.sec.gov/Archives/edgar/data/873860/000162828017005576/0001628280-17-005576-index.htm OCWEN DOCUMENT: http://shareholders.ocwen.com/static-files/1bb3f1eb-1b57-415e-a951-3fbe73d019f8 OCWEN FILINGS Goldman Sachs aka Goldman Sachs Group, Inc. www.ocwen.com at least 99% of the voting

securities of Goldman Sachs Mortgage Company and, thus, bears full responsibility for its actions.

The following are significant subsidiaries of The Goldman Sachs Group, Inc. as of December 31,

2016 and the states or jurisdictions in which they are organized. Each subsidiary is indented beneath its

principal parent. The Goldman Sachs Group, Inc. owns, directly or indirectly, at least 99% of the

voting securities of substantially all of the subsidiaries included Below (excerpt from table that

includes Goldman Sachs & Goldman Sachs Mortgage Company.

Name State or Jurisdiction of Organization of Entity

The Goldman Sachs Group, Inc. Goldman, Sachs & Co.

Goldman Sachs Paris Inc. et Cie Goldman Sachs Bank USA Goldman Sachs Mortgage Company

GS Financial Services II, LLC

Delaware New York France New York New York Delaware

SOURCE: http://www.goldmansachs.com/investor-relations/financials/current/10k/2016-10-k.pdf ALL SEC FILINGS

SEC 10K: https://www.sec.gov/Archives/edgar/data/886982/000119312515056785/d840464d10k.htm

CIK Company State/Country 0000886982 GOLDMAN SACHS GROUP INC

SIC: 6211 - SECURITY BROKERS, DEALERS & FLOTATION COMPANIES formerly: GOLDMAN SACHS GROUP INC/ (filings through 2008-03-04)

NY

0000904571 GOLDMAN SACHS GROUP INC formerly: GOLDMAN SACHS GROUP LP (filings through 2000-04-10)

NY

SOURCE -- SEC: https://www.sec.gov/cgi-bin/browse-edgar?company=goldman+sachs+group&owner=exclude&action=getcompany

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Defendants have not completed the investigation of all the facts of this case, or discovery in, or analysis of

this matter, and have not completed preparation for trial. Accordingly, this disclosure is provided pursuant to

Rule 26 of the Federal Rules of Civil Procedure without prejudice to Defendants’ rights to introduce at trial any

evidence that is subsequently discovered relating to proof of presently known facts, and to produce and introduce

all evidence whenever discovered relating to the proof of subsequently discovered material facts. Moreover,

facts, documents and things now known may be imperfectly understood and, accordingly, such facts, documents,

and things may not be included in the following statement. Defendants reserve the right to refer to, conduct

discovery with reference to, or offer into evidence at the time of trial any and all facts, documents and things

notwithstanding the initial statements herein. Defendants further reserve the right to refer to, conduct discovery

with reference to, or offer into evidence at the time of trial any and all facts, documents and things which they do not

presently recall, but may recall at some time in the future.

PLAINTIFF: These requests are obscene. The defendants’ current counsel has had 5 years to

prepare for trial but chose to spend their time trying to subvert the Plaintiff’s efforts to be

heard. Further, defendants’ and their attorneys should have conducted turnover sessions to

transfer information from the defendants and all previous law firms to Duane Morris. In the

spirit of fairness and the Plaintiff’s right to a “speedy trial”, the Plaintiff believes the discovery

countdown should begin March 10, 2018, the day after the latest extension was granted to the

defendants.

Defendants object to the disclosure of information that is protected by the attorney-client privilege, the work

product doctrine or any other applicable privilege. To the extent that Defendants inadvertently disclose information

that may be protected from discovery under the attorney-client privilege, the work product doctrine or any other

applicable privilege, such inadvertent disclosure does not constitute a waiver of any such privilege.

PLAINTIFF: The Plaintiff believes that the defendants told her that HSBC was paying for all

defendants in an effort to intimate her. The defendants’ should not be rewarded for their

failure subvert the Plaintiff.

The information set forth below is provided without in any manner waiving: (1) the right to object to the use

of any response for any purpose, in this action or any other actions, on the grounds of privilege, relevance, materiality,

or any other appropriate grounds; (2) the right to object to any requests involving or relative to the subject matter of

the responses herein; (3) the right to revise, correct, supplement or clarify any of the responses provided below, at

any time. Defendants specifically reserve the right to supplement their responses herein in accordance with the

Federal Rules of Civil Procedure and the local rules of the District of New Jersey.

PLAINTIFF: The Plaintiff contends that 13 years of deception and subversion by the defendants,

obviates their requests. Moreover, given that the Plaintiff is one person against a bastion of

attorneys from Duane Morris, a 1,610 employee firm (https://www.linkedin.com/company/duane-

morris-llp) and Stern & Eisenberg, a 120 employee firm (https://www.linkedin.com/company/stern-&-

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eisenberg), the only extensions provided should be to secure responses from the Plaintiff’s

subpoenas.

Finally, the Plaintiff requests that the defendants cite the specific rules from the Federal Rules

of Procedure 2018 Edition and the specific rules from the District of New Jersey.

A. Veronica Williams: Plaintiff has information concerning the facts and circumstances giving rise to the Complaint.

PLAINTIFF: I have provided everything that I can think of in the 3500+ pages of filings with the

U.S. District Court of New Jersey except what needs to be corroborated by witness testimony

or documents that will be subpoenaed.

B. Designated Representative(s) of Ocwen Loan Servicing, LLC (“OLS”). OLS objects to any ex parte contact by Plaintiffs of any designated individuals employed by OLS. Ocwen also objects to providing the address and telephone numbers of such employees. These employees may be contacted through Brett L. Messinger, Duane Morris LLP, 30 S. 17th Street, Philadelphia, PA 19103. The Designated Representative(s) have information concerning Plaintiff’s claims, including but not limited to the loan servicing history, including but not limited to Plaintiff’s requests for a loan modification agreement.

PLAINTIFF: Most witnesses are former employees. Plaintiff will contact them directly. Kevin

Flanagan has not been contacted by Plaintiff and will be contacted through Brett Messinger.

C. Designated Representative(s) of Litton. Litton objects to any ex parte contact by Plaintiffs of any designated individuals employed by Litton. Litton also objects to providing the address and telephone numbers of such employees. These employees may be contacted through Brett L. Messinger, Duane Morris LLP, 30 S. 17th Street, Philadelphia, PA 19103. The Designated Representative(s) have information concerning Plaintiff’s claims, including but not limited to Plaintiffs’ requests for a loan modification agreement and the servicing of Plaintiff’s Loan while Litton was the loan servicer.

PLAINTIFF: Most witnesses are former employees. Plaintiff will contact them directly.

E. Designated Representative(s) of HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage-Backed Certificates, Series 2006-C. HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage-Backed Certificates, Series 2006-C objects to any ex parte contact by Plaintiffs of any designated individuals employed by HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage-Backed Certificates, Series 2006-C. HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage-Backed Certificates, Series 2006-C. HSBC Bank USA, N.A., Freemont Home Loan Trust 2006-C Mortgage- Backed Certificates, Series 2006-C also objects to providing the address and telephone numbers of such employees. These employees may be contacted through Brett L. Messinger, Duane Morris LLP, 30 S. 17th Street, Philadelphia, PA 19103. The Designated Representative(s) have information concerning Plaintiff’s claims.

PLAINTIFF: Plaintiff began sending copies to defendants when Stuart Seiden of Duane Morris

stopped responding to her inquiries and communicating with her. This is documented in

filings. Plaintiff will send all future correspondence for the aforementioned defendants to

Brett Messinger, Duane Morris.

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F. Designated Representative(s) of Goldman Sachs Mortgage Company (incorrectly pled as Goldman Sachs). Goldman Sachs Mortgage Company (incorrectly pled as Goldman Sachs)objects to any ex parte contact by Plaintiffs of any designated individuals employed by Goldman Sachs Mortgage Company (incorrectly pled as Goldman Sachs). Goldman Sachs Mortgage Company (incorrectly pled as Goldman Sachs) also objects to providing the address and telephone numbers of such employees. These employees may be contacted through Brett L. Messinger, Duane Morris LLP, 30 S. 17th Street, Philadelphia, PA 19103. The Designated Representative(s) have information concerning Plaintiff’s claims.

PLAINTIFF: Goldman Sachs was not incorrectly pled. Most people listed as Goldman Sachs

witnesses are no longer employed by Goldman Sachs. location pursuant to Rule 26(a)(1)(B) as follows:

A. Documents concerning Plaintiff’s account while it was serviced by Litton. Such documents are in the possession, custody or control of OLS.

PLAINTIFF: These documents are based on a fraudulent mortgage concocted between Litton

Loan and Fremont. Proof is referenced throughout case filings including USDCNJ Docs # 41

(41) and # 58 (58). Evidence will be further corroborated by witness testimony and subpoena

responses.

B. Documents concerning Plaintiff’s account while it was serviced by OLS. Such documents are in the possession, custody or control of OLS.

PLAINTIFF: Based on the testimony of Owen’s employee, these documents are based on

fraudulent information from Litton Loan.

2. ss

3. COMPUTATION OF DAMAGES CLAIMED

Defendants are not seeking damages from any party at this time.

PLAINTIFF: Most people will see this for what it is – a dog whistle. The defendants should have

learned by now that unlike their opposing attorneys and others, I will not back down from

threats, personal attacks or other pressure. I am of good courage:

1 Peter 3:13-14 13 Who is going to harm you if you are eager to do good? 14 But even if you should suffer for what is right, you are blessed. “Do not fear their threats; do not be frightened.”

1 Chronicles 28:20 David also said to Solomon his son, “Be strong and courageous, and do the work. Do not be afraid or discouraged, for the LORD God, my God, is with you. He will not fail you or forsake you until all the work for the service of the temple of the LORD is finished.

Psalm 56:4 4 In God, whose word I praise— in God I trust and am not afraid. What can mere mortals do to me?

I do not fear the defendants and threats will not deter me. Rather, I become more determined

and dig in. If the defendants or their counsel choose to file a legal claim against me, I will file a

counterclaim and fight with everything that God gives me. My story will be told. I prefer that it

be told in the U.S. District Court of New Jersey.

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4. INSURANCE AGREEMENTS

There are no insurance agreements under which any person carrying on an insurance business

may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or

reimburse for payments made to satisfy the judgment.

PLAINTIFF: The American Modern Home Insurance Company could have some liability for the

defendants’ actions. Two of their employees are on the Plaintiff’s subpoena list. This

information is referenced in USDCNJ filings.

“American Modern Home Insurance Group (AMIG Claim# 2393384, www.amig.com )

responded to my claim. According to AMIG, Litton was paid $584 for damages to the

insured property, yet none of that payment was spent on repairs to that property.”

SOURCE: Discovery document, Exhibit 41 p. 7 http://southorangegem.officethatworks.com/download/HAMP_Request_8-4-14-SHARE.pdf or USDCNJ p. 1104 http://www.finfix.org/US-Case-No-2-16-cv-05301-ES-JAD.pdf

I, the Plaintiff, look forward to my day in Court. The defendants’ continued delays and lack of cooperation with USDCNJ confirm that I owe it to my fellow New Jersey residents to present my case in open Court.

Respectfully submitted,

Veronica A. Williams Pro Se Counsel

/s/ Veronica A. Williams Veronica A. Williams [email protected]

February 12, 2018 Phone (202) 486-4565

.

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Page 12 of 18

ATTACHMENT II

Defendant’s Feb. 9, 2018 Document

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Page 13 of 18

ATTACHMENT II cont’d.

Defendant’s Feb. 9, 2018 Document

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Page 14 of 18

ATTACHMENT II cont’d.

Defendant’s Feb. 9, 2018 Document

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Page 15 of 18

ATTACHMENT II cont’d.

Defendant’s Feb. 9, 2018 Document

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Page 16 of 18

ATTACHMENT II cont’d.

Defendant’s Feb. 9, 2018 Document

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Page 17 of 18

ATTACHMENT II cont’d.

Defendant’s Feb. 9, 2018 Document

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Page 18 of 18

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

http://www.njd.uscourts.gov/

Civ. No. 2:16-cv-05301-ES-JAD

CERTIFICATION OF SERVICE

I, Veronica Williams, certify that on this 12th day of February 2018, a true and correct copy of this document will be given to counsel or sent to the parties via the method and as addressed below:

Via Email & U.S. Mail Brett Messinger, Partner [email protected]

Stuart I. Seiden, Associate [email protected]

Attorneys for Litton Loan Servicing, HSBC Bank USA, Goldman Sachs, Ocwen, Fremont Home Loan trust 2006-C Mortgage-Backed Certificates Series 2006-C

Duane Morris LLP 30 South 17th Street Philadelphia, PA 19103-4196 Phone (215) 979-1124 Fax (215) 827-5536 [email protected]

Via Email & U.S. Mail Evan Barenbaum, Esq Attorney for Stern & Eisenberg Director of Litigation Stern & Eisenberg, PC 1581 Main Street, Suite 200 Warrington, PA 18976 Office 267-620-2130 Cell 215-519-2868 Fax 215-572-5025 [email protected] [email protected]

Via U.S. Mail Attorney General for the State of NJ Mr. Gurbir S. Grewal Attorney General Office of The Attorney General The State of New Jersey Richard J. Hughes Justice Complex (HJC) 25 Market Street 8th Floor, West Wing Trenton, NJ 08625-0080

Respectfully submitted,

Veronica A. Williams Pro Se Counsel

/s/ Veronica A. Williams [email protected]

February 13, 2018 Phone (202) 486-4565

VERONICA A. WILLIAMS,

Plaintiff,

v.

LITTON LOAN SERVICING, HSBC BANK USA, N.A. ; GOLDMAN SACHS; FREMONT HOME LOAN TRUST 2006-C MORTGAGE- BACKED CERTIFICATES , SERIES 2006-C; OCWEN; STERN & EISENBERG, PC, Ocwen Financial Corporation

Defendants.


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