You forgot the best part!And the award for "Excellence in Creative Writing" in the Foreclosure Action Category goes to FD and his Atty Habib:
From the motion:
Plaintiff’s action, which Defendants FOTIS DULOS and FORE GROUP, LLC intend to present to this Honorable Court, as follows:
- (1) The alleged mortgage debt has been satisfied;
- (2) The Plaintiff is not the owner of the alleged debt;
- (3) The Plaintiff is not the holder of the alleged Note;
- (4) The Plaintiff is not authorized or otherwise entitled to enforce the terms of the alleged Mortgage and the alleged Note.
- (5) The alleged mortgage debt is erroneous;
- (6) Defendants contest the amount of debt claimed by the Plaintiff;
MOO
(7) The alleged non-payment of the installment(s) of principal and interest pled in the Plaintiff’s Complaint, and the alleged default resulting therefrom, was due to mistake or accident, and upon tender of such installment(s) the Defendants must be relieved of any alleged default which may have occurred by reason of the alleged failure to pay the installment(s) when due, and the Defendants must be relieved of any forfeiture which might ensue by reasons of such alleged default;
The part where FD has to sign a sworn affidavit stating what mistake or accident occurred which led to the mortgage not being paid for a year!!!!