Loughren V Lion Et Al Complaint in Equity

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
PATRICKJ. LOUGHREN,
Plaintiff,
v.
KATHLEEN M. LION, MARTIN BAIR,
BARBARANNE GROARK, LAURA BRYANS,
AMALTAKSAOUI, KELLY KULPA, ELIJAH
CIVIL ACTION EQUITY
LEWIS, CAROL CONNELL, JESSICA
CARTAGENA, JACLYN JAMIESON,
NO. GD-lO
NASTASSJA FALTERBAUER, EILEEN
O'BRIEN, LISA SODA, NANCY SCHMEHL,
COMPLAINT IN EQUITY
DANIELLE DOUGHERTY, SCOTT LION,
MARTIN HYNES, TINAMARIE BOSCHETTI,
BRIDGET MARIE SPECK, MICHELLE
CLARKSON,SHERRIPETERSON,LORETTA
CRESPO, NICHOLAS BARONE, LOURDES
Filed by Plaintiff, pro se
GERENA, NATALIE ROWAN, KYLE
MAHONEY, DIANA MONTANEZ, CHERYL
Patrick J. Loughren, Esquire
DILCHUS, MICKIE KELLY, NANCY
PA ID #80449
KELLEHER, TABITHA WILSON, JOYCE
Loughren, Loughren & Loughren, P.C.
GARCIA, ERIC KEENAN, BARBARA L.
310 Grant Street
HAND, ANTOINETTE BLACK, and
Suite 2800 Grant Building
GOLDBECK, McCAFFERTY & McKEEVER,
Pittsburgh, Pennsylvania 15219
P.C.,
Telephone: 412-232-3530
Facsimile: 412-232-3535
Defendants.
JURY TRIAL DEMANDED

PATRICKJ. LOUGHREN,
CNIL ACTION EQUITY
Plaintiff,
NO. GD-IO
v.
KATHLEEN M. LION, et al.
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses and objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property of other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO

NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
Lawyer Referral Service

Allegheny County Bar Association
11 th Floor Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
Telephone: (412) 261-5555
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PATRICKJ. LOUGHREN, CIVIL ACTION - EQUITY
Plaintiff, NO. GD-to
vs.
KATHLEEN M. LION, et al.
Defendants.
COMPLAINT IN EQUITY
AND NOW, comes the Plaintiff, Patrick J. Loughren, pro se, and files the following
Complaint averring as follows:
I. INTRODUCTION
This is an action to enjoin non-lawyers from engaging in the unauthorized practice of law,
which conduct, in Pennsylvania, is a crime. The Defendants in this action, with the exception of
Goldbeck, McCafferty & McKeever, P.C., are all non-lawyers. These non-lawyers prepare
foreclosure complaints, sign lawyers' names to those complaints, and file those complaints in
county courts across this Commonwealth without an attorney ever having read the document.
The instant such lawsuits are filed, the unauthorized practice of law has been committed. Thus,
upon the filing of the document, a crime has been committed. After they file the foreclosure
complaints in the manner described above, the non-lawyers prosecute the actions, and in doing so
they prepare, sign and file affidavits purporting to be signed by lawyers, but which are in fact
signed by non-lawyers. These documents serve the ultimate purpose of the non-lawyers, which is
to maximize recovery of "attorney fees" through foreclosure and sale of the property. In the
lawsuits they file, these non-lawyers claim "attorney's fees". As a result of the lawsuits, the non-
lawyers recover "attorney fees" from Mortgagors directly, in the event the loan is reinstated, or
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from the proceeds of the sale of the mortgaged property in the event that the foreclosure results in
sale of the property. The non-lawyers are assisted by Notary Publics, also defendants herein, who
notarize documents at the request of the non-lawyers, some of which documents falsely purport to
bear the signatures of lawyers, but which in fact are merely non-lawyers forging lawyers'
signatures. Thus, the Notary Defendants aid and abet the non-lawyers in committing the
unauthorized practice of law by providing them with false documents necessary to achieve
foreclosure. Plaintiff seeks to enjoin this unauthorized practice of law, protect his profession and
the integrity of the judicial process, disgorge the defendants of all illegal fees recovered and
restore the monies to the Mortgagors from whom the monies were taken.
II. PARTIES
A. Plaintiff
1. Plaintiff, Patrick J. Loughren, is an adult individual and a member of the bar of the
Commonwealth of Pennsylvania. Plaintiff is a trial lawyer who maintains a principal place of
business at 310 Grant Street, Suite 2800, Pittsburgh, Pennsylvania 15219.
B. Non-Lawver Defendants
2. Kathleen M. Lion is on information and belief the Director of Human Resources
and Office Administration at Goldbeck, McCafferty & McKeever, P.C. (hereinafter "GMM"),
Suite 5000, Mellon Independence Center, 701 Market Street, Philadelphia, Pennsylvania 19106.
3. Defendant, Martin Bair is on information and belief the Manager of Administrative
Support at GMM.
4. Defendant, Barbaranne Groark, is on information and belief the Director of Office
Administrations at GMM.
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5. Defendant, Laura Bryans, is on information and belief the Manager of Quality
Control & Training at GMM
6. Defendant, Amal Taksaoui, is on information and belief the Administrative
Services Manager of the HR Department at GMM
7. Defendant, Kelly Kulpa, is on information and belief the Team Leader of the
Referrals/Complaint department at GMM
8. Defendant, Elijah Lewis, is on information and belief a member of the
9. Defendant, Carol Connell, is on information and belief a supervisor In the
10. Defendant, Jessica Cartagena, is on information and belief a member of the
11. Defendant, Jaclyn Jamieson, is on information and belief a member of the
12. Defendant, Nastassja Falterbauer, is on information and belief a member of the
Referrals/Complaint department at GlVIM
13. Defendant, Eileen O'Brien, IS on information and belief a member of the
14. Defendant, Lisa Soda, is on information and belief a Supervisor of the
15. Defendant, Nancy Schmehl, IS on information and belief a member of the
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16. Defendant, Danielle Dougherty, is on infonnation and belief a member of the
17. Defendant, Scott Lion, is on infonnation and belief a Supervisor of the Judgment
department at GMM
18. Defendant, Martin Hynes, is on infonnation and belief a member of the Judgment
departmentatGMM
19. Defendant, Tinamarie Boschetti, is on infonnation and belief a member of the
JudgmentdepartmentatGMM
20. Defendant, Bridget Marie Speck, is on infonnation and belief a member of the
Judgment department at GMM
21. Defendant, Michelle Clarkson, IS on infonnation and belief a member of the
Judgment department at GMM
22. Defendant, Sherri Peterson, is on infonnation and belief a member of the Judgment
department at GMM
23. Defendant, Loretta Crespo, is on infonnation and belief the Supervisor of the
Service department at GMM
24. Defendant, Nicholas Barone, is on infonnation and belief the member of the
Service department at GMM
25. Defendant, Lourdes Gerena, is on infonnation and belief the member of the Service
department at GMM
26. Defendant, Natalie Rowan, is on infonnation and belief the member of the Service
department at GMM
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27. Defendant, Kyle Mahoney, is on infonnation and belief the member of the Service
department at GMM
28. Defendant, Diana Montanez, is on infonnation and belief a member of the
Complaint, Judgment, Log In Department at GMM
29. Defendant, Cheryl Dilchus, is on infonnation and belief the Supervisor of the
Litigation Department at GMM
30. Defendant, Mickie Kelly, is on infonnation and belief the Manager of the
LitigationIREO/Title Curative Department at GMM
31. Defendant, Nancy Kelleher, is on infonnation and belief, a member of the
32. Defendant, Tabitha Wilson, IS on infonnation and belief, a member of the
33. Defendant, Joyce Garcia, is on infonnation and belief, a member of the Litigation
Department at GMM.
34. Defendant, Eric Keenan, is on infonnation and belief, a legal secretary at GMM.
c. The Notary Public Defendants
35. Defendant, Barbara L. Hand, is an adult individual who, on infonnation and belief,
is a member of the "Judgment" department at GMM. On infonnation and belief, Defendant Hand
is and was at all times material hereto commissioned by the Secretary of the Commonwealth of
Pennsylvania as a Notary Public pursuant to The Notary Public Law, 57 P.S. § § 147-168.3.
36. Defendant, Antoinette Black, is on infonnation and belief, the Manager of the Sales
Department at GMM. Defendant Black is and was at all times material hereto commissioned by
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the Secretary of the Commonwealth of Pennsylvania as a Notary Public pursuant to The Notary
Public Law, 57 P.S. § § 147-168.3.
D. The Law Firm Defendant
37. Defendant GOLDBECK, MCCAFFERTY & MCKEEVER, P.e. (hereinafter
"GMM") is a professional corporation maintaining a principal place of business at Suite 5000,
Mellon Independence Center, 701 Market Street, Philadelphia, Pennsylvania 19106.
38. Plaintiff is suing GMM only for its vicarious liability for the conduct of the Non-
Lawyer defendants described herein. Plaintiff is not suing GMM for any conduct committed by
the attorneys at GMM as such conduct falls under the jurisdiction of the Office of Disciplinary
CounseL
III. JURISDICTION AND VENUE
39. The illegal practice of a profession is a proper subject of equitable jurisdiction. See
Childs v. Smeltzer, 315 Pa. 9, 171 A. 883 (1934), Boggs v. Werner, 372 Pa. 312,317,94 A. 2d 50,
51-52 (1953) (dentistry); Palmer v. O'Hara, 359 Pa. 213, 58 A. 2d 574 (1948) (medicine); Neill v.
Gimbel Bros., Inc., 330 Pa. 213, 199 A. 178 (1938) (optometry); Matter of Arthur, 15 B.R. 541
(Bankr. RD. Pa. 1981) (law).
40. Pennsylvania law provides that, "In addition to criminal prosecution, unauthorized
practice of law may be enjoined in any county court of common pleas having personal jurisdiction
over the defendant. The party obtaining such an injunction may be awarded costs and expenses
incurred, including reasonable attorney fees, against the enjoined party." See 42 Pa.C.S. 2524 (c).
41. The Pennsylvania Supreme Court has stated, "The fact that the unauthorized
practice of law is a criminal offense does not, however, deprive a court of equity of jurisdiction to
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enjoin ongoing unauthorized practice. It is well settled that the criminal remedy is inadequate to
protect the public from continuing unauthorized practice and that an injunction may properly
issue." Dauphin County Bar Asso. v. Mazzacaro, 465 Pa. 545, 551, fn 4 (Pa. 1976) citing Shortz
v. Farrell, 327 Pa. 81, 193 A. 20 (1937); Childs v. Smeltzer, 315 Pa. 9, 171 A. 883 (1934);
American Bar Foundation, Unauthorized Practice Handbook 99 (J. Fischer & D. Lachman eds.
1972); Dobbs, Remedies 117 (1973); Note, Remedies Available to Combat the Unauthorized
Practice ofLaw, 62 Col.L.Rev. 501, 504 (1962); cf. Everett v. Harron, 380 Pa. 123, 110 A.2d 383
(1955); Boggs v. Werner, 372 Pa. 312, 94 A.2d 50 (1953).
42. An injunction has been regarded as a proper remedy to prevent the illegal practice
oflaw as well as other professions. See 16 P.L.E., COURTS § 392 citing Ginsburg v. Kovrak, 392
Pa. 143, 139 A.2d 889 (1958)(law), Shortz v. Farrell, 327 Pa. 81, 193 A. 20 (1937)(law), Dauphin
County Bar Asso. v. Mazzacaro, 465 Pa. 545, 351 A.2d 229 (1976)(law) and Childs v. Smeltzer,
315 Pa. 9,171 A. 883 (1934)(law); Boggs v. Werner, 372 Pa. 312,94 A.2d 50 (1953)(dentistry);
Palmer v. O'Hara, 359 Pa. 213, 58 A.2d 574 (1948)(medicine).
43. Venue is proper because Defendants regularly and systematically engage in the
conduct described hereinafter in the Allegheny County.
IV. STANDING
44. Loughren has standing to invoke this Court's equity jurisdiction to enjoin the
unauthorized practice of law. Jurisdiction is invokable on the complaint of a duly licensed
member of the profession unlawfully so invaded. Palmer v. O'Hara, 359 Pa. 213, 227, 58 A.2d
574,581 (Pa.1948)
45. As one court has stated, "It must be borne in mind that it has always been held that
a professional man has standing to prevent the improper invasion of his profession...... [T]he
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right to practice a profession is for many equitable purposes a property right; that such injunctive
action is in the nature of a suit to restrain improper and unlawful competition; that each
professional man bears a responsibility to the public for the proper practice of his profession and
that suit to enjoin improper professional practice is a proper effort to enjoin a public nuisance."
Felix v. Wax, 1958 Pa. Dist. & Cty. Dec. LEXIS 357; 13 Pa. D. & C.2d 600, 604 (Phila. Cty.
1958)
v. FACTUAL ALLEGATIONS
A. The Unauthorized Practice of Law by Non-Lawyers Working at Goldbeck,

McCafferty & McKeever, P .C.
46. The Supreme Court in this Commonwealth is empowered by Article V, Section
1O(c} of the Pennsylvania Constitution to govern the conduct of attorneys practicing law within
the Commonwealth.
47. Pursuant to its constitutional authority, the Pennsylvania Supreme Court adopted
the Rules of Professional Conduct and the Rules of Disciplinary Enforcement, which govern the
conduct and discipline of attorneys. Commonwealth v. Stern, 549 Pa. 505, 701 A.2d 568,571
(pa.1997).
48. The Non-Lawyer defendants herein are non-lawyers. They are not subject to the
Rules of Professional Conduct or the Rules of Disciplinary Enforcement.
49. The Non-Lawyers are not" ... bound by a reviewable code of professional ethics
designed to deter [them] from the temptations of self-interest which can frequently arise in the
course oflegal representation." Dauphin County Bar Asso. v. Mazzacaro, 465 Pa. 545 , 555, FN6
351 A.2d 229, 234, FN6 (Pa. 1976)
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50. On infonnation and belief, the Non-Lawyer Defendants have filed hundreds, if not
thousands of foreclosure lawsuits in the Courts of Common Pleas of the Commonwealth of
Pennsylvania that have been written, signed and filed by these Defendants without any attorney
having reviewed the document.
51. The Defendants make it appear as if a lawyer has read, reviewed, and signed the
document by either typing lawyers' names on the documents, signing lawyers' names to the
documents, or both, but the fact of the matter is that no lawyers have read, reviewed, or signed the
documents.
52. The deposition of GMM was taken on September 21, 20 lOin the case of Kimberly
A. Robinson v. Countrywide Home Loans, Inc., et al. No. 08-cv-01563 currently pending in the
United States District Court for the Western District of Pennsylvania.
53. As the Court is aware, a witness designated to testify pursuant to Federal Rule of
Civil Procedure 30(b)(6) speaks on behalf of the corporate entity and the testimony of the designee
is binding on that entity.
54. The witness designated by GMM to testify on its behalf on September 21, 2010
was Gary McCafferty, Esquire. Mr. McCafferty is both a named partner and shareholder of
GMM.
55. Mr. McCafferty admitted that the Non-Lawyer Defendants file prepare, sign and
file foreclosure lawsuits that have ~ been reviewed by any attorney:
Q. Was it the practice in 2006 that Complaints could be filed without

an attorney reviewing the Complaint?
A. It could be, yes.
Q. Did the finn authorize its administrative staff, which I'll just
describe as non-lawyers, so inclusive of secretaries, paralegals,
legal assistants, to sign attorneys' names to Complaints and file
them, knowing that the attorney had not read the document?
A. Yes.
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56. Joseph Goldbeck, Esquire is "of counsel" to GMM and is a fonner shareholder and
fonner actively practicing attorney at GMM. Mr. Goldbeck was also deposed on September 21,
20 lOin the matter of Robinson v. Countrywide, supra. During his deposition, Mr. Goldbeck
testified that non-lawyers were authorized to not only write up foreclosure lawsuits, but to sign his
name to the lawsuits and file those lawsuits without him ever even seeing the document:
Q. Back in 2006, you were an active practicing lawyer at the finn?

A. Yes.
Q. And did you authorize individuals who were employed at the finn
who were not lawyers to write up Complaints and sign your name
to them and file them without you reviewing them?
A. Yes, I did.
57. The third-named partner in GMM, Michael T. McKeever, Esquire, has testified that
the non-lawyers at GMM are engaged in the widespread unauthorized practice of law. While
testifying at a hearing on December 8, 2009 in the matter of DeAngelis v. Countrywide Home
Loans, Inc. (In Re: Hill), 2010 Bankr. LEXIS 3313 (Bankr. WD Pa. 2010), Mr. McKeever
admitted that it was "standard practice" in 2007 for non-lawyers to write up foreclosure lawsuits,
sign lawyer's names to said lawsuits, and file said lawsuits prior to any lawyer reviewing the
lawsuit:
Q. There's a signature page on the foreclosure complaint, and it's actually

signed by -- or there's a signature there of Mr. Joseph A. Goldbeck, Jr.,
correct?
A. Yes.
Q. But Mr. Goldbeck did not sign this; is that correct?
A. No, he authorized someone to.
Q. But Mr. Goldbeck did not review this document, did he?
A. No, he did not.
Q. Okay. He authorized someone to what, stamp his name on this?
A. I think that's a -- I don't believe that's a stamp, but it may be.
Q. Okay. I'm sorry, I -- is it that someone signed his name for him, is that what
you're saying?
A. Yes.
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Q. Okay. Do you know who did?
A. I don't, no.
Q. And this was standard practice at your firm in 2007, correct?
A. Yes, it was.
58. Mr. McKeever further admitted that the practice continued at GMM through the
date of his testimony, to wit, December 8, 2009:
Q. In 2007, if this foreclosure checklist did not indicate a reason to request

supervision, am I to understand that the foreclosure complaint was
filed without attorney review?
A. In 2007, yes.
Q. Does that still happen today?
A. Yes, unless there's issues that arise that indicate an attorney should review
the file.
B. The Non-Lawyers Perform No Investigation
59. Before they file the lawsuits that they both prepare and sign attorneys' names to,
the Non-Lawyer Defendants perform no investigation into the facts and/or circumstances giving
rise to the claim.
60. On information and belief, some of the foreclosure lawsuits that the Non-Lawyer
Defendants file are filed against Mortgagors who have FHA-Insured loans pursuant to the Federal
Housing Administration (FHA) established under Subchapter II of the National Housing Act, 12
U.S.C. § 1701 et seq.
61. The Secretary of the Department of Housing and Urban Development has
promulgated regulations establishing certain conditions precedent to a Mortgagee's right to
foreclose upon an FHA-Insured loan. See 24 C.F.R. §§ 203.500 et seq.
62. A violation of FHA regulations can, at a minimum, serve as an affirmative defense
to the foreclosure action. See Fleet Real Estate Funding Corp. v. Smith, 366 Pa. Super. 116; 530
A.2d 919 (pa. Super. 1987)("'Today we follow the lead of these decisions and hold that a
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mortgagor of an FHA-insured mortgage may raise as an equitable defense to foreclosure, the
mortgagee's deviation from compliance with the forbearance provisions of the HUD Handbook
and regulations.")
63. In fact, FHA-Insured loans typically contain provision within them that specifically
limit the Mortgagees' right to accelerate the debt and/or foreclosure prior to compliance with FHA
Regulations. A typical provision states:
9. Grounds for Acceleration of Debt
(d) Regulations of HUD Secretary. In many circumstances

regulations issued by the Secretary will limit Lender's
rights, in the case of payment default, to require immediate
payment in full and foreclose if not paid. This Security
Instrument does not authorize acceleration or foreclosure if
not permitted by regulations of the Secretary.
64. Mr. McCafferty (on behalf of the firm) testified that the Non-Lawyer Defendants
make no independent undertaking to determine whether the FHA regulations have been complied
with before they (i.e. the non-lawyers) file the lawsuits that they (i.e. the non-lawyers) have
written up, signed and filed without a lawyer having reviewed the document:
Q. Does the firm have a practice when it gets a new case to sue
somebody for foreclosure in the situation of an FHA loan, that the
firm will undertake affirmatively to determine whether or not the
FHA regulations were complied with that are prerequisites to filing
the foreclosure case?
A. There's no independent undertaking.
Q. What does that mean?
A. It means that the firm does not go back and examine whether the
client has complied with whatever regulations.
Q. The FHA regulations?
A. Correct.
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65. In fact, during its deposition taken on September 21, 2010, Mr. McCafferty
testified that the non-lawyers who are filing these lawsuits have no training with regard to FHA
regulations:
Q. Does the firm have any training of its employees or continuing

legal education requirements that lawyers who sue people to take
their houses from them have a good understanding about what the
regulations are in the event the loan is an FHA loan?
A. I would say that the staff is not trained in FHA regulations.
66. On information and belief, the non-lawyers working at the firm knowingly filed
lawsuits against Mortgagors - that had not been reviewed by any attorney and they did so
despite knowing that the Mortgagors had absolute defenses to the lawsuits premised upon the
failure of the creditors to comply with FHA regulations.
67. The lawsuits were filed despite the fact that they were meritless because the Non-
Lawyers knew that the Mortgagors were either too unsophisticated to appreciate the defenses
available to them, to economically destitute to hire a lawyer to raise the defenses on their behalf,
or both.
VI. 42 PA.C.S. §2424(a) Has Been Repeatedly Violated
6S. The preparation and filing of a pleading constitutes the practice of law in this
Commonwealth.
69. The federal courts applying Pennsylvania law have held that the filing of petitions
in bankruptcy by non-lawyers constitutes the unauthorized practice of law. See In Re: Poconos
Land, LLC, 343 B.R. lOS, 112 (MD Pa. 2005)(" ... this Court concludes that the filing of the
petitions at issue by non-attorneys on behalf of an artificial business entity constitutes the practice
oflaw in the Commonwealth of Pennsylvania.")
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70. In Pennsylvania, the unauthorized practice of law is a crime and is regulated by
statute, 42 Pa.C.S. § 2524(a) which states, in relevant part:
(a) General Rille. -- Except as provided in subsection (b), any person,

including, but not limited to, a paralegal or legal assistant, who within this
Commonwealth shall practice law, or who shall hold himself out to the
public as being entitled to practice law, or use or advertise the title of
lawyer, attorney at law, attorney and counselor at law, counselor, or the
equivalent in any language, in such a manner as to convey the impression
that he is a practitioner of the law of any jurisdiction, without being an
attorney at law or a corporation complying with 15 Pa.C.S. Ch. 29 (relating
to professional corporation), commits a misdemeanor ofthe third degree
upon a first violation. A second or subsequent violation of this subsection
constitutes a misdemeanor of the first degree.
71. In Pennsylvania, an "attorney at law" is a person "admitted to the bar of the courts
of this Commonwealth." See 42 Pa.C.S. § 2521.
72. To practice law a person must demonstrate a reasonable mastery of legal skills and
principles, be a person of high moral character and maintain a continuing allegiance to a strict
code of professional conduct.
73. The requirements that must be met to engage in the practice law exist so that the
public is protected. The Pennsylvania Supreme Court in Shortz et al. v. Farrell, 327 Pa. 81, 193
A. 20 (Pa. 1937) has explained this purpose as follows:
"While in order to acquire the education necessary to gain admission to the bar and
thereby become eligible to practice law, one is obliged to 'scorn delights, and live
laborious days,' the object of the legislation forbidding practice to laymen is not to
secure to lawyers a monopoly, however deserved, but, by preventing the intrusion
of inexpert and unlearned persons in the practice oflaw, to assure to the public
adequate protection in the pursuit of justice, than which society knows no loftier
aim.".
74. The non-lawyers working at GMM whose conduct is described hereinabove are
engaged in the unauthorized practice oflaw.
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75. When each and every complaint in foreclosure has been filed that has been written
by a non-lawyer, had a lawyer's name signed to it by a non-lawyer, and been filed by a non-lawyer
without any attorney having read the document, the crime of the unauthorized practice of law has
been committed.
76. GMM has authorized the conduct of the non-lawyer defendants, and has profited
from it as described hereinafter. GMM is vicariously liable for the conduct of its non-lawyer
employees who are defendants herein.
77. The non-lawyers are being paid by their "clients", through payments made to
GMM, to engage in habitual drafting and filing of legal instruments that are filed in courts across
the Commonwealth without any lawyer having read same. This constitutes the practice of law.
Northampton County Bar Ass'n. v. Young,1 Monroe L.R. 94, 26 North 363 (1939) See also Matter
ofBradford ARTHUR 15 RR. 541; 1981 Bankr. LEXIS 2522 (B.R. ED Pa. 1981)
78. It is axiomatic that a corporation may appear and be represented in our Courts only
by an attorney duly admitted to practice. Walacavage v. Excell, 331 Pa. Super. 137; 480 A.2d 281
(Pa. Super. 1984) Smaha v. Landy, 162 Pa. Commw. 136, 638 A.2d 392 (Pa. Cmwlth.), petition
for allowance of appeal denied, 539 Pa. 660, 651 A.2d 546 (1994); Fire Prot. Indus. v. Scimeca
Found., Inc., 2006 Phila. Ct. Com. PI. LEXIS 495 (Phila Cty 2006)
79. The hundreds or thousands of cases that have been prepared by, signed by, and
filed by the Non-Lawyer Defendants without attorney review are all lawsuits that have been
filed illegally in violation of the statute prohibiting the unauthorized practice of law. The alleged
"appearance" by the lawyers whose names appear on the documents is a fraud on the Court, as the
lawyers have admitted, under oath, that they have never reviewed the documents written and :filed
by these non-lawyers. Thus, the non-lawyers who put the lawyers' names on the documents are
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committing both a crime when they file the documents, and a fraud on the Court when they
represent to the Court, via attorney signature, that an attorney has reviewed the document. (This
latter point is more fully explained below in connection with Pa.R.C.P. 1021(c»
80. No lawyer has prepared, read, investigated, studied, considered, and/or
contemplated the facts of the lawsuit, the claims being asserted, or the merit of the lawsuit.
81. Plaintiff avers, on information and belief, that the "clients" of the non-lawyers
consisting of banks, loan servicers, REMIC trusts, and other creditors are all aware that the non-
lawyers are engaged in the unauthorized practice of law. The individuals employed at these
entities (i.e. at the "clients") all interact with the Non-Lawyer Defendants on a day-to-day basis
via email and/or phone and they are aware that the Non-Lawyers are responsible for preparing,
signing and filing these foreclosure cases and that the cases are being filed without any attorney
review.
82. The "clients" of the Non-Lawyer Defendants pay for the services of the Non-
Lawyers and, on information and belief, receive some or all of the illegal fees that the Non-
Lawyers collect as a result of their unauthorized practice oflaw.
83. On information and belief, numerous foreclosure actions that have been filed by the
non-lawyers at GMM are currently pending. All of these actions must be dismissed. A complaint
filed by a non-lawyer purporting to represent a third-party is a nullity.
84. The Honorable Michael McCarthy of the Court of Common Pleas of Allegheny
County has stated, "Proceedings commenced by persons unauthorized to practice law are a nullity,
and an appeal pursued by an individual unauthorized to practice law may be quashed by an
appellate court pursuant to a tribunal's obligation to raise jurisdictional questions sua sponte." Am.
Nat'l Ins. Co. v. Hollind Holdings, Inc., 2010 Pa. Dist. & Cnty. Dec. LEXIS 89 (Alleg. Co.
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201O)(citing Spirit of the Avenger Ministries v. Commonwealth of Pennsylvania, 767 A.2d 1130
(Pa Cmwlth 2001); McCain v. Curione, 106 Pa Cmwlth 552, 527 A.2d 591 (1987); Winters v.
Sheporwich, 1952 Pa. Dist. & Cnty. Dec. LEXIS 311; 83 Pa. D. & C. 484 (1952)
85. Federal Courts construing Pennsylvania law are in accord with Judge McCarthy's
holding. See Marin v. Leslie, 2008 U.S. Dist. LEXIS 80287 (WD Pa. 2008) affirmed in part and
modified in part by Marin v. Leslie, 2009 U.S. App. LEXIS 15138 (3d Cir. Pa., July 8,
2009)("When a non-lawyer has commenced a proceeding on behalf of a legal entity, the court fails
to obtain jurisdiction over the lawsuit.") See also, Eveready Battery Co. v. Clements Export &
Import, 1991 U.S. Dist. LEXIS 14197; 20 Fed. R. Servo 3d (ED Pa. 1991)("Since the defendant
corporation's Answer and Counterclaim was executed by the sole corporate shareholder and not by
an attorney, said Answer and Counterclaim must be stricken.")
86. Every foreclosure action pending in every Court of Common Pleas in this
Commonwealth that has been prepared by and filed by the Non-Lawyer Defendants, without
attorney review, should be dismissed on the basis that the Court lacks jurisdiction over the lawsuit.
87. According to the testimony of GMM, Mr. Goldbeck and Mr. McKeever set forth
hereinabove - the Non-Lawyer Defendants engaged in this practice from at least 2006 through at
least December 8,2009.
88. However, on information and belief, and for reasons that will be made clear
hereinafter, Plaintiff avers that the Non-Lawyers continued their criminal conduct even after
December 8, 2009. Moreover, on information and belief, the practice of the Non-Lawyer
Defendants filing lawsuits for third parties without any lawyer having read the lawsuit pre-dated
2006.
19
VII. Violation ofPa.R.C.P.1023.l(c)
89 Each and every time that a Non-lawyer Defendant signs an attorney's name to a
foreclosure complaint - knowing that no lawyer has read or reviewed the complaint and that
document is subsequently filed with the Court, in addition to being the final act in the commission
of a crime, the conduct also violates Pennsylvania Rule of Court 1023 .1 (c).
90. Pennsylvania Rule of Court 1023.1(c) states:
( c) The signature of an attorney or pro se party constitutes a certificate that the

signatory has read the pleading, motion, or other paper. By signing, filing,
submitting, or later advocating such a document, the attorney or pro se party
certifies that, to the best of that person's knowledge, information and belief,
formed after an inquiry reasonable under the circumstances,
(1) it is not being presented for any improper purpose, such as to harass
or to cause unnecessary delay or needless increase in the cost of
litigation,
(2) the claims, defenses, and other legal contentions therein are
warranted by existing law or by a nonfrivolous argument for the
extension, modification or reversal of existing law or the
establishment of new law,
(3) the factual allegations have evidentiary support or, if specifically so

identified, are likely to have evidentiary support after a reasonable
opportunity for further investigation or discovery; and
(4) the denials of factual allegations are warranted on the evidence or, if
specifically so identified, are reasonably based on a lack of
information or belief.
91. When the Non-Lawyers sign lawyer's names to complaints and file those
documents with the Courts knowing that the documents have not been read or reviewed by the
lawyers, the certification appearing on the document (Le. the signature) is fraudulent and the Non-
Lawyers are knowingly committing a fraud on the Court for at least three reasons.
92. First, the certification that a lawyer had read the lawsuit is blatantly false.
20
93. Second, the certification that the lawyer whose named has been signed to the
document has performed a reasonable inquiry into the merit of the case is blatantly false since no
lawyer has done any inquiry, let alone a reasonable inquiry.
94. Third, certification that the "claims" set forth in the Foreclosure Complaint are
meritorious and nonfrivolous is blatantly false. Each of these complaints sets forth claims for
"attorney fees". Since no attorney has prepared, signed or done any work filing the lawsuits, no
attorney's fees are due. Moreover, and more fundamentally, since the Complaint itself is a nullity,
the claim for attorney's fees is frivolous, false and fraudulent and can never exist even if a lawyer
does read it sometime thereafter and actually work on the file. A nullity is a nullity and the
criminal "bell" can't be un-rung.
95. Pennsylvania Rule of Civil Procedure 1023.3 permits the Court to sua sponte issue
a Rule to Show Cause upon Defendant GMM and the Non-Lawyer Defendants requiring them to
show cause why they are not culpable of the widespread, systematic violation of Rule 1023.1(c).
96. Because the Non-Lawyer Defendants engage in their criminal conduct under the
auspice of the letterhead of the law firm GMM, and because they often use electronic signatures to
further their criminal purposes, they have hidden the true nature of their conduct from both the
public, the mortgagors they have sued, and from the Honorable Judges of the Courts of Common
Pleas. Plaintiff brings this action to not only advise the Courts of the widespread conduct, but to
enjoin it as well.
VIII. The Attorneys' Fees Claims of Non-Lawvers
97. The most egregious course of conduct - aside from the commission of the
unauthorized practice of law as part of taking someone's home - is that the non-lawyers who file
21
these cases without attorney review include claims for attorneys' fees as part of the relief
requested. These claims for attorney's fees are false, fraudulent, frivolous and unfounded.
98. Plaintiff is a trial lawyer who firmly believes that all persons - including creditors
such as Banks who have issued mortgage loans have the right to enforce their rights, including
the contractual right to foreclose where permitted by both the law and the facts. Plaintiff in no
way believes or seeks to enjoin creditors from legally pursuing their rights. However, the Non-
Lawyers and the "clients" they serve are blatantly violating the law, and they are taking from
Mortgagors far more than they are legally entitled to.
99. The Non-Lawyer Defendants are claiming substantial sums of money from
Mortgagors - in the form of alleged attorneys fees - that are not due and owing by the
Mortgagors. Thus, all Mortgagors who have paid "attorney fees" have been wronged, and the
Non-Lawyers and their Bank "clients" have converted the Mortgagors' property.
100. The Non-Lawyers and their clients are not desirous of Mortgagors reinstating their
loans, even though such reinstatements do result in payment of illegal "attorneys fees".
101. The Non-Lawyers and their "clients" prefer foreclosure. This is because at
foreclosure, they can illegally claim higher amounts of illegal attorney fees which are paid from
the sale of the mortgaged property or, on information and belief, by various government programs
and/or insurers.
102. In order to achieve foreclosure, however, the Non-Lawyers must commit other
criminal and fraudulent conduct. The non-lawyers file Writs of Execution and other documents
(including affidavits of last known address) upon which they forge lawyers' signatures, often
before a notaries public working at the firm, such as Defendant Hand and Defendant Black, both
of whom knowingly violate their duties as a Notaries Public, (as set forth in great detail below).
22
103. The property is then sold and "attorney's fees" are recovered by Defendants, even
though no attorney has worked on the matter andlor even though the "attorney fees" recovered
bear no relationship, let alone a reasonable relationship, to any work that was done by an attorney.
104. Importantly, the right to claim any attorney's fees arises out ofthe documents upon
which the lawsuits are filed, to wit, the Note and/or the Mortgage.
105. There is no question that neither the Note, nor the Mortgage, nor the law authorize
or permit MortgageeslNoteholders to collect "attorneys fees" where no lawyer has done any work
or as a reward for the commission of a crime.
106. In other cases where non-lawyers have sued Mortgagors, the Mortgagors are able to
scrape up the money to pay the demands being made upon them by non-lawyers. These monies
include alleged "attorney fees" even though no lawyer has done anything to prepare or file the
foreclosure action. These Mortgagor/Homeowners overpay to reinstate their loans.
107. All of the monies recovered by the Non-Lawyers and their "clients" as a result of
the foreclosure actions filed by these Non-Lawyers should be accounted for, and returned to the
Mortgagors from whom they were taken.
IX. The Forgeries
108. While the admissions of the law firm GMM, Goldbeck and McKeever during
deposition testimony set forth hereinabove clearly establish the basis of this action, Plaintiff
independently confirmed that documentary evidence exists that corroborates the testimony. This
documentation is discussed below, and some of it (but certainly not all of it) is attached hereto by
way of exemplar.
109. In connection with collecting "attorney's fees" as a reward for committing the
unauthorized practice of law, and in order to obtain those fees by effectuating the sale of the
23
foreclosed upon home, the non-lawyers routinely forge lawyers names on documents other than
complaints, including affidavits that purport to be signed in the presence of a Notary Public. The
non-lawyers working at GMM know such documents are fraudulent but they use them
nevertheless as the instrumentalities of their widespread commission of the unauthorized practice
oflaw.
110. By way of example, an Amended Complaint in Foreclosure was filed October 7,
2008 in the matter of Bank of New York as Trustee for the Certificateholders of CWMBS 2005-RI
v. Kimberly Robinson, No. GD06-030787. The signature page of the document is attached as
Exhibit 1 and purports to be signed by Michael T. McKeever, Esquire whose signature appears as
follows:
By: Nb~
GOLDBECK McCAFFERTY &McKEEVER
By: MICHAEL T. MCKEEVER, ESQUIRE
ArrORNEY FOR PLAINTIFF
111. The signature of Mr. McKeever in Robinson is much different than the signature of
Mr. McKeever on a Complaint filed 11103/08 in JPMorgan Chase Bank Natl Assoc vs Hays-
McGinley GD-08-023649, Allegheny County. The signature page in Hays-McGinley is attached
as Exhibit 2 and the signature appears as follows:
24
cCAFFERTY & McKEEVER
T. KEEVER, ESQUIRE
FOR PLAINTIFF
112. Indeed, in the Hays-McGinley case, Mr. McKeever's alleged signature on the
complaint (supra) is different that his signature on the verification to the Complaint attached as
Exhibit 3, which appears as follows
ichael T. cKeever,
PA I.D. #56129
113. Another example of Mr. McKeever's alleged signature, appearing on the signature
page (attached as Exhibit 4) on a Complaint filed 11103/08 in Citimortgage Inc. vs Boland GD-08-
023651, Allegheny County, where the signature appears as follows:
25
By:
--~~~~~~~~----~~~~~~~~----------
GOLDB CK cCAFFERTY & McKEEVER
By: MICHAEL T. McKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
114. Even when signed before !! Notary Public, the signature of Mr. McKeever
appears in many different forms.
115. For example, his name is signed to an "Affidavit of Last Known Address"
allegedly signed by Mr. McKeever before Notary Public Barbara Hand on February 5, 2008 and
filed of record on February 6, 2008 in the case of Countrywide Home Loans1nc. vs Raeder etal,
GD-07-018833, Allegheny County. This affidavit is attached as Exhibit 5 and the signature
appears as follows:
26
Affidavit of Last Known Address
I. Michael T. McKeever, Esquire. hereby verify that I am counsel of record for the Plaintiff, COUNTRYWIDE
HOME LOANS INC.; that as such and in my capacity as such, I am authorized to execute the within Affidavit for and
on behalf of Plaintiff; that to the best of my knowledge, information, and belief, the names and last known addresses
of the Owner(s) and Defendant(s) in the above referenced proceeding are MARK A. RAEDER, 3037 SW 5th
Avenue, Cape Coral, FL 33914 and DEBRA J. RAEDER, 5231 Brightwood Road #1. Bethel Park, PA 15102; I
further understand that false statements herein made are subject to the provisions set forth in 18 Pa.C.SA 4904
relating to unsworn falsifications to authorities.
Attorney for Plaintiff
Sworn to and subscribed

Before me this ~ day
of 2008
COMMONWEAl.TM OF PENN8Yl.VANIA
NOTARIAl.. SE:AL
~ L HAND, NoIaIyPubllc
City of PhlIadeIphIa, PhIIa. CocIIly
My ComnllSSion ElIpi!as.klne 19,20','
116. Mr. McKeever allegedly appeared before Notary Public Barbara L. Hand and
signed his name to an affidavit (attached as Exhibit 6) filed April 7, 2009 in Citimortgage Inc. vs
Boland GD-08-023651, Allegheny County, and his signature on the affidavit in Boland appears as
follows:
27
AFFJDAVITOF COMPLIANCE WITH ACT'60F 1974,41 P.S. 101, ET.SEQ.
AND ACT' 91 OF 1983
COMMONWEALTH OF PENNSYLVANIA)
)
) SS:
)
COUNTY OF ALLEGHENY )
Before me, the undersigned authority, a Notary Public in and for th aid Co and
Commonwealth, personally appeared Michael T. McKeever, attorney fo e Plai ff, who being duly
sworn accOrding to law deposes and says that on, Defendant(s) was! re rna' a a Notice(s) of
Homeowner's emergency Mortgage Assistance Act ofl983 and 6 N 'ce(s) oflntention to Foreclosure
by certified mail, return receipt requested and first class U,S. M ,
SWORN TO AND SUBSeRI ED
ME THIS L DA '1 ,.....l.fLl·-'\4PLUl~.
NotalY Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAl
BARBARA L HAND, Notary Public
City of Pf'Jladelphia, f'hiIa. County
l\1y CommiSsion Expires June 19, 2010
117. The alleged signature of Mr. McKeever on the Affidavit of Compliance set forth
below was allegedly signed in the presence of Notary Public Barbara L. Hand. The document,
attached as Exhibit 7, was filed May 1,2009 in LaSalle Bank National Association vs Moore etal
GD-08-023656, Allegheny County:
28
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974,41 P.S. lOt. ET.SEQ.
AND ACT 91 OF 1983
)
) SS:
)
Before me, the undersigned authority, a Notary Public in and for the said County and
Commonwealth, personally appeared Michael T. McKeever, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that on , Defendant(s) was/were mailed a Notice(s) of
Homeowner's emergency Mortgage Assistance Act of 1983 and Act 6 Notice(s) of Intention to Foreclosure
by certified mail, return receipt requested and first class U.S. Mail.
SWORN TO AND SUBSCRIBEDI EFORE
~~
ME THIS DAYOF ,2009, NOTARIAL SEAl
~R8ARA l. HAND, Notary Public
City 01 Philadelphia, Phi/a. County
My Commission Expires June 19, 2010
Notary Public
118. On January 23, 2009, an Affidavit of Compliance, attached as Exhibit 8, was
allegedly signed by Mr. McKeever before Notary Public Barbara L. Hand in the case of National
City Mortgage Co. vs Cancilla GD-08-023703, Allegheny County, and the signature appears as
follows:
29
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974, 41 P.S. 101, £I.SEQ.
AND ACT 91 OF ]983
)
) SS:
)
Commonwealth, personally appeared Michael T. McKeever, attorney for the Plaintiff, who being duly i
sworn according to law deposes and says that on , Dy,fendant(s) was/were mailed a Notice(s) of I
Homeowner's emergency Mortgage Assistance Act of 1983 and Act 6 Notice(s) oflntention to Foreclosu,re
by celtified mail, return receipt requested and first class U.S. Mail. I
I
I
I,
1
. III",• .., • TAAIIu.. SEAL .,

~AA L HAND NoIaIy
CiIy of Phtf~ 'PilIIa. Public
My~1 &piIBs County
Notary Public June '9,3)10
119. Mr. McKeever allegedly signed an "Affidavit Pursuant to Rule 3129", attached as
Exhibit 9, before Notary Public Antoinette Black on July 15, 2008 that was filed on July 17,2008
in Deutsche Bank National Trust Company vs Johnson GD-07-020865, Allegheny County, as
follows:
30
(J)jfi~ o11f/1flmM
DATED: July IS, 2008
oOLJ)Jj(i <CAfFERTY & McKEEVER
BY; Micl1ael T. McKeever, Esq.
Attorney for Piaililiff

Befmemethis I~ day
of ~ ,2008
~Public NOla!)'
120. In the same case, Deutsche Bank National Trust Company v. Johnson, No. GD-07-
020865, Mr. McKeever's signature appears on a notarized "Affidavit of Last Known Address",
attached as Exhibit 10, as follows:
31
I, Michael T. McKeever, Esquire, hereby verify that I am counsel of record for the Plaintiff, DEUTSCHE
BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF ARGENT MORTGAGE SECURITIES, INC.. ASSET
BACKED PASS THROUGH CERTIFICATES, SERIES 2OO6-M1 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF JUNE 1, 2006, WITHOUT RECOURSE; that as such and in my capacity as such, I
am aulhori2:ed to execute !he within Affidavit for and on behalf of Plaintiff; \hal to the best of my knowiedge,
information, and belief, !he names and last known addresses of the Owner(s) and Defendant(s) in the above
referenced proceeding are BARRY W. JOHNSON, 3450 McClure Avenue, Pitts rgh,
understand thai false statements herein made are subject to the provisions set orlh in
unsworn falsifications to authorities.
121. The signature of Mr. McKeever appearing on the Affidavit of Compliance filed in
Cancilla, see ~ 86 supra, is vastly different than the signature of Mr. McKeever appearing on the
Complaint filed in the very same case (i.e. Cancilla) which appears immediately below (signature
page from Complaint in Cancilla attached hereto as Exhibit 11):
... _- - - - - J:
BY:_~oo~~~-rIYl~cM~. ........:.-tel_-_
GOLDBECK McCAFFERTY & McKEEVER
122. On information and belief, Defendant McKeever did not sign all of the documents
reference hereinabove, nor did he appear before a Notary Public and sign all of the documents
described hereinabove that were allegedly signed in the presence of a Notary Public.
32
123. The alleged signature of Joseph Goldbeck appears on an "Affidavit of Last Known
Address" attached hereto as Exhibit 12, filed 12/29/06 in the case of MTGLO Investors LP vs
Kobu1insky et aI, No GD-06-023420:
I, Joseph A. Goldbeck, Jr., Esquire, hereby verify that I am counsel d record for the Plaintiff, MTGLQ
INVESTORS, LP; that as such and in my capacity as such, I am authorized to execute the wilhin Affidavit fa and on
behalf of Plaintiff; that to the best of my kno>Medge, information, and belief, tile names and lasl known addresses of
!he CNiner(s) and Defendant(s} in !he above referenced proceeding are ROBIN A. KOBULINSKY, 710 Church
Street Ext, Turlle Creek, PA 15145 and RICHARD W. KOBULINSKY, 710 Church Street Ext, Turlle Creek, PA
15145; I furlher understand that false stataments herein made are subject to the provisions set fath in 18 Pa.C.SA
4904 relating to unsworn falsificalioos to authorities.

Be ore me this L day
124. The signature of Mr. Goldbeck appears on the Complaint filed in the Kobulinsky
matter is very different that the signature filed in the same case before Notary Public. The
signature appearing on the signature page of the complaint, which is attached hereto as Exhibit 13,
looks like this:
33
G014~""'.aJ
By:
125. The signature of Mr. Goldbeck appears on an Affidavit of Last Known Address,
attached hereto as Exhibit 14, filed on 5/31107 in the case of Citifinancial Services Inc. vs Harper
etal, GD-06-023422, Allegheny County, as follows:
34
I, Joseph A. Goldbeck, Jr., Esquire, hereby verify thai I am counsel of record for the Plaintiff, GITIFINANClAl
SERVICES INC.; thai as such and in my capacity as such, I am authorized 10 execute the within Affid4vit for and on
behaWof Plaintiff; that 10 the best of my knowledge, information, and belief, the names and last known addresses of
the Owner(s) and Defendan~s) in the above referenced proceeding are JAMES EHARPER, 1190 Fot:est Ave Apt
#4, Pittsburgh, PA 15236 and MARGARET MHARPER, 1190 Forest Ave Apt #4 ittsburgh, PA 15236; I further
understand that false statements herein made are subject 10 the provisions
unsworn falsifications 10 authorities.
Sworn to and subscnDed

'sLday
126. The signature of Joseph Goldbeck appears on the signature page of the complaint,
attached hereto as Exhibit 15, filed in Citifinancial Services Inc. vs Arthur GD-06-023421,
Allegheny County as follows:
35
· JOSEPH A. GOLDBECK, JR., ESQUIRE
RNEY FOR PLArNTIFF
127. On information and belief, Mr. Goldbeck did not sign all of the documents set forth
above that bear his signature and, on information and belief, there are hundreds if not thousands of
documents that bear his signature that he has not signed which documents have been signed by the
non-lawyers working at GMM who are engaged in the widespread unauthorized practice oflaw.
128. The reason that no lawyers are signing the documents utilized in foreclosing on
homes across Pennsylvania is because no lawyers are, in fact, involved in filing these lawsuits, no
lawyers are involved in defaulting the Mortgagors, and no lawyers are involved in reducing the
defaults to judgment and sale at foreclosure. Rather, the lawsuits are being filed and prosecuted to
conclusion by non-lawyers who are engaged in the unauthorized practice oflaw.
129. On December 29, 2009, a Verification of Non-Military Service attached hereto as
Exhibit 16 was filed in the case of Citimortgage Inc. vs Lower, Allegheny County, M G-09-002231
as part of a Praecipe to Enter Default Judgment. The document is notarized by Defendant Hand
and purports to bear the signature of Mr. McKeever.
130. On information and belief, the signature appearing on Exhibit 16 is not Mr.
McKeever's.
131. On December 31, 2009, an Affidavit of Compliance was filed in Lower as part of a
Praecipe for Writ of Execution. The document attached hereto as Exhibit 17 is notarized by
Defendant Hand and purports to bear the signature of Mr. McKeever.
36
132. On infonnation and belief, the signature appearing on Exhibit 17 is not Mr.
McKeever's.
133. The complaint in JPMorgan Chase Bank NA. vs Morgan, Allegheny County, MG-
09-003126 was filed December 9, 2009.
134. The signature on the complaint purports to be that of Mr. McKeever, but on
infonnation and beliefthe signature is not Mr. McKeever's signature and was placed there by one
of the Defendant Non-Lawyers engaging in the unauthorized practice oflaw.
135. A Praecipe for Default Judgment was filed in the Court of Common Pleas of
Allegheny County on January 21,2010 in Morgan. Appended to the document was a Verification
of Non-Military Service, sworn before Defendant Hand. This document, attached hereto as
Exhibit 18, was sworn January 21,2010, but is dated January 19, 2010.
136. On December 9, 2009, a foreclosure complaint was filed in Citimortgage Inc. vs
Alberts et ai, Allegheny County, MG-09-003129, purportedly signed by Mr. McKeever.
137. On infonnation and belief, the complaint in Alberts was not signed by Mr.
McKeever.
138. On December 11, 2009, a foreclosure complaint was filed in Deutsche Bank
National Trust Company vs Sisco, Allegheny County, MG-09-003150. Both the signature page to
the complaint and the verification to the complaint, attached hereto as Exhibits 19 and 20,
respectively, purport to be signed by Mr. McKeever.
139. On infonnation and belief, one of the Non-Lawyer Defendants engaged in the
unauthorized practice of law signed Exhibits 19 and 20.
37
140. On December 14, 2009, a foreclosure complaint was filed in Wells Fargo Bank
Minnesota vs. Wheeler et aI, Allegheny County, MG-09-003174.
141. The signature page to the complaint, attached hereto as Exhibit 21, purports to be
signed by Mr. McKeever.
142. On information and belief, Mr. McKeever did not sign the complaint in Wheeler
but, rather, the document was signed by Non-Lawyer Defendants engaged in the unauthorized
practice oflaw.
143. On December 17,2009, a foreclosure complaint was filed in Citimortgage Inc. vs
Boyle et aI, Allegheny County, MG-09-003204 and the signature on the complaint, attached as
Exhibit 22, purports to be that of Mr. McKeever.
144. On information and belief, Mr. McKeever did not sign the complaint in Boyle.
145. On February 4,2010, Defendant Boschetti signed her own name to a "Verification
of Military Service" in Boyle that purports to be an affidavit of Mr. McKeever. This document is
attached as Exhibit 23. The document is sworn to and subscribed before a notary public, to wit,
Defendant Hand. The opening paragraph of the document states, "MICHAEL T. MCKEEVER,
hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on
information and belief, he has knowledge of the following facts, to wit ... "
146. In other words, Defendant Boschetti swore to an affidavit on behalf of Mr.
McKeever, swearing that she knew what information was inside Mr. McKeever's mind, which is
so patently absurd it bears no further comment, except to note that apparently Notary Hand had no
problem permitting this outrageous conduct.
147. On June 17, 2010, Defendant Keenan (who is a secretary) filed an affidavit
claiming to be Mr. McKeever in Boyle. This document is attached hereto as Exhibit 24.
38
148. Plaintiff has reviewed numerous documents filed of record wherein Defendant
Keenan signed affidavits purporting to swear to the knowledge that was inside Mr. McKeever's
head. One such affidavit was an Affidavit Pursuant to Rule 3129 filed June 24, 2010 in
Citimortgage Inc. vs Turner Jr., Allegheny County, MG-1O-000405, which is attached hereto as
Exhibit 25, and which document was notarized by Defendant Black. The document bears the date
June 15,2010 but the notary stamp indicates that it was signed June 21, 2010.
149. In a Supplemental Affidavit filed August 27,2010 in Deutsche Bank National Trust
Company vs Lemp et ai, Allegheny County, MG-10-000406, Defendant Keenan (a legal secretary)
again signed an affidavit, attached hereto as Exhibit 26, purporting to know what is inside Mr.
McKeever's head. The document purports to be notarized by Defendant Black, however,
Defendant Black did not even sign the document, revealing either that Defendant Black is careless
with her notary seal, or she has given it to others who are so anxious to take people's homes while
engaged in the unauthorized practice oflaw that they cannot even "properly" forge a document.
150. In an affidavit attached hereto as Exhibit 27 and filed September 17, 2010, BAC
Home Loans Servicing L.P. vs HUe, Allegheny County, MG-I0-001409 Defendant Keenan again
executed an affidavit before a notary that purports to attest to the knowledge inside Mr.
McKeever's head.
151. On information and belief, in addition to the documents described hereinabove,
Defendants Hand and Black (the Notary Public Defendants) notarized hundreds, if not thousands
of documents in violation of the Notary Public Law, Act of August 21, 1953, P.L. 1323, as
amended, 57 P .S. § 168.
152. The documents that have been notarized by Defendants Hand and Black, such as
the documents set forth hereinabove, have been used by the Non-Lawyer Defendants to foreclose
39
on homes and to collect illegal so-called "attorneys fees" that are being charged by non-lawyers
committing the crime of the unauthorized practice oflaw.
153. Defendants Hand and Black have knowingly aided and abetted the non-lawyers to
engage in the unauthorized practice of law; they have violated their duties as Notaries; they have
stained and undermined the truth finding process and the integrity of the Judicial System. Their
conduct is criminal, and their conduct is outrageous.
154. Defendants Hand and Black should be enjoined from aiding and abetting in the
unauthorized practice oflaw.
X. JUDGMENTS OBTAINED ILLEGALLY
155. The widespread criminal conduct described herein is not the result of excusable
neglect or inadvertence. Rather, it is the result of greed on the part of the Non-Lawyers and the
"clients" they serve while hiding under the letterhead of the law firm Goldbeck, McCafferty &
McKeever. Since Non-Lawyers can never have "clients" as that term is used by Courts and those
who have earned the right and obtained the honor of being admitted to the practice oflaw, Plaintiff
puts the word "clients" in quotations when referring to the "clients" of the Non-Lawyers.
156. The prohibition against the unauthorized practice of law set forth in 42 Pa.C.S.
2524(a) specifically contemplates that paralegals and legal assistants hiding under the letterhead of
a law firm may attempt to engage in the unauthorized practice of law, and the law specifically
makes such conduct a crime. 42 Pa.C.S. § 2524(a) states:
(a) General Rule. -- Except as provided in subsection (b), any person,

including, but not limited to, a paralegal or legal assistant, who within this
Commonwealth shall practice law, or who shall hold himself out to the
public as being entitled to practice law, or use or advertise the title of
lawyer, attorney at law, attorney and counselor at law, counselor, or the
equivalent in any language, in such a manner as to convey the impression
that he is a practitioner of the law of any jurisdiction, without being an
40
attorney at law or a corporation complying with 15 Pa.C.S. Ch. 29 (relating
to professional corporation), commits a misdemeanor of the third degree
upon a first violation. A second or subsequent violation of this subsection
constitutes a misdemeanor of the first degree. (Emphasis added.)
157. On information and belief, no lawyer working at Goldbeck, McCafferty &
McKeever instructed these Non-Lawyer Defendants to prepare and fIle false affidavits, or to claim
and/or recover "attorney fees" in cases where no lawyers had done any work whatsoever.
158. Where a non-lawyer has engaged in the unauthorized practice of law and has
obtained a judgment on behalf of his or her "client", any such judgment should be vacated. The
Court had no jurisdiction over the lawsuit, the judgment is the result of the commission of a crime,
and neither the non-lawyer nor the "client" of the non-lawyer should profit from such conduct.
159. The Prothonotary in all such cases was without authority to enter judgment against
the defendants. The judgments are, therefore, void ab initio. See Mullen v. Slupe, 360 Pa. 485,
490, 62 A.2d 14, 16 (1948) Gudgment "entered without authority ... is no judgment at all so far as
it affects the rights of the defendants. ") (quoting Long v. Lemoyne Borough, 222 Pa. 311, 318 71
A. 211, 212 (1908».
XI. PENDING FORECLOSURE CASES FILED IN VIOLATION OF LAW
160. With respect to pending foreclosure actions fIled by non-lawyers at GMM engaging
in the unauthorized practice of law, such lawsuits should be immediately dismissed, as the Court
has no jurisdiction over them. The lack of jurisdiction cannot be cured by having attorneys come
in and claim that they will now respect the rule of law. These Complaints were a nullity when the
were fIled.
41
161. Anything less than dismissal of cases filed in violation of the prohibition against
the unauthorized practice of law by non-lawyers encourages such conduct to be repeated. (See
Chase v. City of Earle, 2010 U.S. Dist. LEXIS 48230 (ED Ark. 2010)("When a non-lawyer
attempts to represent the interests of other persons, the practice constitutes the unauthorized
practice oflaw and results in a nullity. Jones ex rel. Jones v. Correctional Medical Services, 401
F.3d 950, 952 (8th Cir. 2005). Moreover, a later appointed attorney cannot cure the complaint of
its original defect. Davenport v. Lee, 348 Ark. 148, 155, 72 S.W.3d 85, 88 (2002). This rule
protects the courts interests in ensuring that parties are represented by people knowledgeable and
trained in the law. Jones, 401 F.3d at 952.")
162. Plaintiff avers, on information and belief, that the clients. of GMM knew of,
directed, and profited from the conduct of the non-lawyers described herein. As such, the
"clients" of these Non-Lawyers who are profiteering from the unauthorized practice of law by the
non-lawyers have hands that are as unclean as the Defendants' hands.
163. For example, and without conceding in any manner that their knowledge did not
exist prior to December of 2009, there is no question that Bank of America (which, on information
and belief purchased Countrywide Home Loan, Inc. in July 2008) and BAC Home Loan
Servicing, LP (formerly Countrywide Home Loan Servicing, LP) became aware of the conduct
described hereinabove in December 2009. These entities are only two ofthe entities who the Non-
Lawyers file foreclosures on behalf of.
164. On information and belief, on December 8, 2009, John Smith, Esquire, who was at
the time a current employee of Bank of America and who in 2007 was First Vice President of
Foreclosure, Bankruptcy and Real Estate for Countrywide Home Loans, Inc., was sitting in the
courtroom when Mr. McKeever testified (as set forth hereinabove) that it was "standard practice"
42
for the Defendant Non-Lawyers to engage in the unauthorized practice of law. As an attorney,
Mr. Smith knew of and understood the significance of Mr. McKeever's testimony, to wit, that
non-lawyers working at GMM were and had been filing lawsuits that had not been reviewed by
attorneys and they had been doing it for several years. On information and belief, Mr. Smith also
knew that such conduct was criminal, such lawsuits were nullities, and all such lawsuits should be
dismissed.
165. The next day, December 9, 2009, during court proceedings presided over by
Federal Judge Thomas Agresti in the case of in DeAngelis v. Countrywide Home Loans, Inc. (In
Re: Hill), 2010 Bankr. LEXIS 3313 (Bankr. WD Pa. 2010), Judge Agresti stated on the record:
THE COURT: But I'm a little concerned about what I'm hearing about the
Goldberg firm's handling of cases, filing by paralegals without being, you know,
foreclosure actions being filed without attorneys reading them or reviewing
them before it's filed, filed under signatures that are -- somebody's authorized to
sign a signature -- a name. It's a matter we're going to take up. I don't know if it's
relevant to our proceeding today, but I'm quite concerned with what I'm
hearing.
166. Despite the fact that Bank of America and its lawyers knew, with certainty, in
December of 2009 that hundreds, if not thousands of foreclosures cases pending had been filed by
the non-lawyers in violation of the prohibition against the unauthorized practice of law, they did
not dismiss any of the pending cases filed by the Non-Lawyers for the reason that said cases were
a nullity and, instead, they continued to permit the Non-Lawyers to prosecute those cases to
conclusion - an act of pure greed and disrespect for the Rule of Law.
167. On October 5, 2010, Judge Agresti issued an opinion in In Re: Hill wherein he
stated:
During the trial the Court also became aware of some apparently routine practices
at GMM that raise issues that cannot be ignored. McKeever testified to a
procedure at his firm whereby foreclosure complaints are prepared and filed by
non-attorneys and never reviewed by an attorney, even though the "signature" of
43
an attorney appears on the document. 12/8 Tr. at 83-84. This would seem to be a
violation of the Pennsylvania Rules of Civil Procedure, which provide that the
signature of an attorney on a document filed with a Pennsylvania court is a
certification that the document has been read by the attorney. See Pa.R. Civ.P.
1023.1 (c). Even though these foreclosure actions are not being filed in this Court
and thus do not expose GMM to sanctions, concern for our sister courts in this
Commonwealth compel the Court to at least make publicly known what it learned
during the trial.
In Re: Hill, at **117-118. (emphasis added)
168. Plaintiff is unaware as to whether or not Judge Agresti's efforts have had or will
have any effect on the Non-Lawyer Defendants and their "clients" and, therefore, Plaintiff seeks
an injunction to preserve the integrity of the judicial system and the rule of law in this
Commonwealth, as well as to protect the thousands of Mortgagors who have unknowingly been
sued by Non-Lawyers engaged in the unauthorized practice oflaw and who have paid and/or face
the clear and present danger of paying illegal and fraudulent "attorneys fees" to these Non-
Lawyers and their "clients".
169. On information and belief, there are hundreds, if not thousands of mortgage
foreclosure actions pending in Courts of Common Pleas across the Commonwealth of
Pennsylvania that have been filed by the non-lawyers at GMM in violation of 42 Pa.C.S. §2524(a)
and which are being prosecuted toward judgment by these same individuals. These actions must
be enjoined from further prosecution.
PRAYER FOR RELIEF
Plaintiff respectfully requests that the Court grant the following relief:
1. Declaration that the conduct of the non-lawyers working at Goldbeck,

McCafferty & McKeever, P.C. described herein constitutes the
unauthorized practice of law in the Commonwealth of Pennsylvania;
44
2. An injunction barring the non-lawyers at Goldbeck, McCafferty &
McKeever, P.C. from engaging in the unauthorized practice oflaw within
the Commonwealth of Pennsylvania;
3. An injunction enjoining continued prosecution of any case filed within the

Commonwealth of Pennsylvania in violation of 42 Pa.C.S. §2524(a) by the
non-lawyers at GMM;
4. Issuing a Rule to Show Cause Upon GMM to show cause why all pending
foreclosure actions in the Commonwealth of Pennsylvania in which GMM
has entered an appearance should not be dismissed as having been filed in
violation of 42 Pa.C.S. §2524(a) by the non-lawyers at GMM;
5. Issuing a Rule to Show Cause Why all alleged "attorneys fees" that have
been recovered by the Non-Lawyers or their "clients" in foreclosure
lawsuits filed in violation of 42 Pa.C.S. §2524(a) in the Commonwealth of
Pennsylvania should not be accounted for and returned to the
MortgagorslHomeowners from whom they were taken;
6. Issuing a Rule to Show Cause Upon Defendants to show cause why every
judgment entered in favor of Defendants "clients" in a foreclosure action
filed and prosecuted in violation of 42 Pa.C.S. §2524(a) should not be
opened and/or vacated;
7. Enjoining Defendants from supporting claims or cases in the

Commonwealth of Pennsylvania with false and fraudulent "affidavits"
notarized illegally;
8. Enjoining Barbara L. Hand and Antoinette Black from aiding and abetting
in the commission ofthe unauthorized practice oflaw in the
Commonwealth of Pennsylvania by notarizing documents in violation of the
Notary Public Law which documents are being utilized by non-lawyers at
GMM to prosecute foreclosure actions in violation of 42 Pa.C.S. §2524(a)
9. Enjoining Eric Keenan from signing his name to any legal document to be
filed in any court in this Commonwealth.
10. Enjoining all Non-Lawyer Defendants from signing their names, or the
names of anyone else, upon any document to be filed in any lawsuit
pending in this Commonwealth except in a lawsuit wherein the non-lawyers
are parties, such as this lawsuit.
11. Costs of suit;
12. Any other relief this Honorable Court deems appropriate.
45
Respectfully submitted,
Appearing Pro Se
Address
Loughren, Loughren & Loughren, P.C.
310 Grant Street, Suite 2800
Pittshurgh,Pa 15219
412-232-3530
patrick@loughren.com
46
8. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
. conformity with the Mortgage and Pennsylvania law. Plaintiffis entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
9. Plaintiff is not seeking a judgment ofpersonal1iability (or an "in personam" judgment) against the
Defendants in this Action but reserves its right bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclousre is, in no way, an attempt to re-establish the personal
liabiHty that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
pursuant to Pennsylvania law.
10. The within mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $66,584.36, together with
interest at the rate of $8.10, per day and other expenses incurred by the Plaintiff which are properly chargeable
in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises.
BY:~~.x..:......;...·
~Kt"---4'o'"\~~~~1AI~~~_ _
AlTORNEY FOR PLAINTIFF
EXHIBIT
IeD------=-::-::
06- 0:30181
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
8. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit ''B''. The Defendants have not had the required face-to-face meeting within
the required time and Plaintiffhas no knowledge of any such meeting being requested by the Defendants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $45,058.97,
together with interest at the rate of$8.17, per day and other expenses, costs and charges incurred by the Plaintiff
which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the
Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
By:.~,~~~~-H~~-------------------------
cCAFFERTY & McKEEVER
MIJ~IVEI'. T. KEEVER, ESQUIRE
'T"Tt::.6""~VfFOR PLAINTIFF
EXHIBIT
D- 08-02364'1
VERIFICATION
Michael T. McKeever, Esquire, hereby states that he is

attorney for PLAINTIFF in this matter, that Plaintiff is outside
the jurisdiction of the Court and/or the Verification could not be
obtained wi thin the time allowed for the filing of the pleading
that he is authorized to make this verification pursuant to
Pa.R.C.P 1024 (c) and that the statements made in the foregoing
pleading in the Civil Action in Mortgage Foreclosure are based
upon the information supplied by Plaintiff and are true and
correct to the best of his knowledge, information and belief.
Furthermore, it is the undersigned's intention to substitute a
verification from Plaintiff as soon as it is received by counsel.
The undersigned understands that this statement is made

subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Date: JI '0 d- \ 0 ¥'
EXHIBIT
Ji 3
D- 08- 02.3&4'9
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice oflntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
Counseling Agency.
together with interest at the rate of $19.30, per day and other expenses, costs and charges incurred by the
Plaintiffwhich are properly chargeable in accordance with the tenus of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the~foreClosur~e
of~e Mortgage and Sheriffs Sale of the Property.
By: T~-
GOLDB CK cCAFFERTY & McKEEVER
EXHIBIT
I ~
'D-OB~ 023651
COUNTRYWIDE HOME LOANS INC. ) IN THE COURT OF COMMON PLEAS

Plaintiff ) OF ALLEGHENY COUNTY
Vs. ) CIVIL ACTION LAW
} ACTION OF MORTGAGE FORECLOSURE
MARK A. RAEDER )
DEBRAJ.RAEDER ) GO-O? -018833
Defendant(s) )
I. Michael T. IVIcKeever. Esquire, hereby verify that I am counsel of record for the Plaintiff, COUNTRYWIDE
HOME LOANS INC.; that as such and in my capacity as such, I am authorized to execute the within Affidavit for and
on behalf of Plaintiff; that to the best of my knowledge, information, and belief, the names and last known addresses
of the Owner(s) and Defendant(s) in the above referenced proceeding are MARK A. RAEDER, 3037 SW 5th
Avenue, Cape Coral. FL 33914 and DEBRA J. RAEDER, 5231 Brightwood Road #1, Bethel Park, PA 15102; I
further understand that false statements herein made are subject to the provisions set forth in 18 Pa.C.S.A. 4904
relating to unsworn falsifications to authorities.
~er Attorney for Plaintiff

5" day
Before me this
Of~~2008
NotaryPu IC
NOTARIAl SEAL .
B~aAAAL.HAND,~~
City of Philadelphia, Phlla. County
My CommIssion Expires June 19, 20', '
EXHIBIT
i 5
. D - 01-0185'33
..
CITIMORTGAGE INC. S/BIM

CITIFINANCIAL MORTGAGE COMPANY, CNIL DIVISION
INC.
Plaintiff NO.: GO-08-023651
vs.
JOANN BOLAND as Executrix of the Estate of

Anna M. Crogan, Deceased
Defendant(s)
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF ] 974,41 P.S. 101. ET.SEO.

AND ACT 91 OF 1983
)
) SS:
)
Before me, the undersigned authority, a Notary Public in and for the aid Cou and
Commonwealth, personally appeared Michael T. McKeever, attorney fo e Plai ff, who being duly
sworn according to law deposes and says that on, Defendant(s) wasl re rna' a a Notice(s) of
Homeowner's emergency Mortgage Assistance Act of 1983 and 6 No .ce(s) of Intention to Foreclosure
by certified mail, return receipt requested and first class U.S. M
SWORN TO AND SUBSCRI ED
ME THIS 11- DA ~
NotalY Public
COM~,'iONWEALTH OF PENNSYLVANIA . EXHIBIT

NOTARiAl SEAl..
~RB~ L. HAND, Notary Public
Cny of ~hl~adelphia, Phila. County
I
..
I
I.?
My CommissIon Expires JUne 19, 2010 D-08 - 023 65 I
•
LASALLE BANK NATIONAL

ASSOCIATION, AS TRUSTEE FOR CIVIL DIVISION
CERTIFICATEHOLDERS OF BEAR
STEARNS ASSET BACKED SECURITIES I, NO.: GD-08-023656
LLC, ASSET·BACKED CERTIFICATES,
SERIES 2006-HE7
Plaintiff
vs.
MAMIE A. MOORE
WILLIAM B. MOORE
Defendant(s)
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S. 101. ET.SEQ.

AND ACT 91 OF 1983
)
) SS:
)
Commonwealth, personally appeared Michae1 T. McKeever, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that on, Defendant(s) was/were mailed a Notice(s) of
SWORN TO AND SUBSCRIBED I EFORE
2fb DAY OF ----!~1_4_--, 2009,

COMMONWEALTN OF PENNSYLVANIA
ME THIS NOTARIAL SEAL
B~ABAAA L. HAND. Notary Public
City of Philadelphia, Phila. County
My Commission Expires June 19, 2010
Notary Public
EXHIBIT
I 7
. D- 05 - 0236E6
,NATIONAL CITY MORTGAGE, CO., F/KlA

NATlONAL CITY MORTGAGE, A DIVISION CIVIL DIVISION
OF NATIONAL CITY BANK
Plaintiff NO.: GO-08-023703
vs.
DEANA M. CANCILLA
Defendant(s)
AFFIDAVIT OF COMPLIANCE WITH ACT 6 OF 1974.41 P.S. 101. ET.SEO.

AND ACT 91 OF 1983
)
) SS:
)
Commonwealth, personally appeared Michael T. McKeever, attorney for the Plaintiff, who being duly ,
sworn according to law deposes and says that on, Defendant(s) was/were mailed a Notice(s) of I
Homeowner's emergency Mortgage Assistance Act 6f 1983 and Act 6 Notice(s) ofIntention to Forec1osJ,re
by cel1ified mail, return receipt requested and first class U.S. Mai1. I
II
\I
I
I
I
SWORN TO AND SUBSCRIBED BEFORE II
METHJS :Jl --'"~f-=----' 2009, I

.
COMMONWEAL.TH OF PENNsYLVANIA
BAA NOTARIAL SEAl
I
I
CIty B~ L HAND, Ncmuy Public
My eo::l1r
faOelPf1ja, Pfotila. County
ISSIOlr expIres June 19, 2010
Notary Public I
I
I!
I
I
I
EXHIBIT I
\
I
D- 08-023103 I
I
I
\
..
lJJJ!/J/J~E~f!JM
DATED: July 15,2008
BY: Michael T. McKeever, Esq.

Sworn to and,,- subscribed

Before me this I~ day
of ~ ,200S
~f!tacJ{
Notary Public
COMMO~JWEALTH OF ?ENNSYLVANIA
NOTARIAL SEAL
ANTONIETTE M. BLACK, Notary Public
My Commission Expires Jun~ 27. 2010
EXHIBIT
I 1
. D- Ol- 020865
DEUTSCHE BANK NATIONAL TRUST ) IN THE COURT OF COMMON PLEAS

COMPANY, AS TRUSTEE OF ARGENT ) OF ALLEGHENY COUNTY
MORTGAGE SECURITIES, INC., ASSET ) CIVIL ACTION LAW
BACKED PASS THROUGH CERTIFICATES, ) ACTION OF MORTGAGE FORECLOSURE
SERIES 2006-M1 UNDER THE POOLING AND )
SERVICING AGREEMENT DATED AS OF ) GD-07-020865
)
JUNE 1, 2006, WITHOUT RECOURSE
Plaintiff
Vs.
BARRY W. JOHNSON
Defendant(s)
Affidavit of Last Known Adciress
I. Michael T. McKeever, Esquire, hereby verify that I am counsel of record for the Plaintiff, DEUTSCHE
BANK NATIONAL TRUST COMPANY, AS TRUSTEE OF ARGENT MORTGAGE SECURITIES, INC., ASSET
BACKED PASS THROUGH CERTIFICATES, SERIES 2006-M1 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF JUNE 1, 2006, WITHOUT RECOURSE; that as such and in my capacity as such, I
am authorized to execute the within Affidavit for and on behalf of Plaintiff; that to the best of my knowledge,
information, and belief, the names and last known addresses of the Owner(s) and Defendant(s) in the above
referenced proceeding are BARRY W. JOHNSON, 3450 McClure Avenue. Pitts rgh, A 15212; I further
understand that false statements herein made are subject to the provisions set orth in
Sworn
Befo1i
of --If---~:o«Mr---
COMMONWEAL.TH OF PENNSYLVANIA.
EXHIBIT
I D-Oi-020865
/0
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $119,41 0.49,
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
By:_'---'--!«l~J<V!-'
~ha&~"'-'--_\
~-cJ@~~-,,------
EXHIBIT
I
i II
£:{D- 06- 023 ,03
MTGLQ INVESTORS, LP ) IN THE COURT OF COMMON PLEAS

Vs. ) CIVIL ACTION LAW
) ACTION OF MORTGAGE FORECLOSURE
ROBIN A. KOBULINSKY )
RICHARD W. KOBULINSKY ) GD-06-023420
Defendant{s) )
I, Joseph A. Goldbeck, Jr., Esquire, hereby verify that I am counsel of record for the Plaintiff, MTGLQ
INVESTORS, LP; that as such and in my capacity as such, I am authorized to execute the within Affidavit for and on
behalf of Plaintiff; that to the best of my knowledge, information. and belief, the names and last known addresses of
the Owner{s) and Defendant{s) in the above referenced proceeding are ROBIN A. KOBULINSKY, 710 Church
Street Ext, Turtle Creek, PA 15145 and RICHARD W. KOBULINSKY. 710 Church Street Ext, Turtle Creek, PA
15145; I further understand that false statements herein made are subject to the provisions set forth in 18 Pa.C.S.A.
4904 relating to unsworn falsifications to authorities.
--""-"'--_ day
~I---_ _~~ 2006
,:,;or'f1~::;'~_":~./' r :Tl:~.2:::~:·JNS'{!-'.t,"'. :<:::\

.~.:. '} t ,-f".'t~\L ~~r:AL
CHERV < 'llc: ·US. Notary Public
City of Ph,:' .:,,\1:.. P!lila. County
My Cnr.1:':1!S$!' • ..;::;1 2009
~---<"~"--"~~'~'-'. '-. . ' --
EXHIBIT
i }~
D- 06 - 023420
· liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants
Counseling Agency.
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property.
GO..... ~ ...~JL<
By: OSEPH A. GOLDBECK, JR., ESQUIRE
A TfORNEY FOR PLAINTIFF
EXHIBIT
i I)
6D-06-0?,~4?n
.
.~
.. ' IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA :.
CITIFINANCIAL SERVICES INC. ) IN THE COURT OF COMMON PLEAS

Vs. ) CIVIL ACTION LAW ::
) ACTION OF MORTGAGE FORECLOSURE
JAMES E HARPER )
MARGARET M HARPER ) GD-06·023422
Oefendant(s) )
Affidavit of last Known Address
I, Joseph A. Goldbeck, Jr., Esquire, hereby verify that I am counsel of record for the Plaintiff, ¢ITIFINANCIAl
SERVICES INC.; that as such and in my capacity as such, I am authorized to execute the within Affidi!vit
I
for and on
behalf of Plaintiff; that to the best of my knowledge, information, and belief. the names and last known addresses of
the Owner(s) and Oefendant(s) in the above referenced proceeding are JAMES E HARPER, 1190 For.est Ave Apt
#4, Pittsburgh, PA 15236 and MARGARET M HARPER, 1190 Forest Ave Apt #4 ittsburgh, PA 15236; I further
understand that false statements herein made are subject to the provisions se

Before me .s 2/J day
of _ _....-.-~:.4----'
COMMONWEALTH OF PENNSYL.VANIA
NOTARIAL
BARBARA L HAND. Notary NlUc
ely of ~ PhI&. Cc;uty
My CommIssIon &pires JlIle 19,2010
EXHIBIT
I I If
D-06- 023422
attached hereto as Exhibit "B". The Defendant has not had the required face-to-face meeting within the
required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $74,60 1.02,
together with interest at the rate of $21.21, per day and other expenses costs and charges incurred by the
By:____~~~~~~~~----------------
B : JOSEPH A. GOLDBECK, JR., ESQUIRE
A RNEY FOR PLAINTIFF
EXHIBIT
I 15
- D-()6 - 0284- 2 \
GOLDBECK, MCCAFFERTY & MCKEEVER
By: Michael T. McKeever
Attorney I.D. #56129 ATIORNEY FOR PLAINTIFF
Suite 5000-Mellon Independence Center
701 Market Street
Philadelphia, PA 19106 COURT OF COMMON PLEAS
215-627-1322 CIVIL DIVISION
CITfMORTGAGE INC.
Vs. No. MG-09-002231
ALISON R. LOWER ALLEGHENY COUNTY
VERIFICATION OF NON-MILITARY SERVICE
MICHAEL T. MCKEEVER, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the
above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit:
(a) that the defendant is not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as
amended.
(b) that defendant ALISON R. LOWER is over 18 years of age, and resides at
3602 Shadewell Avenue, Pittsburgh, PA 15227.
(c) that defendant, ALISON R. LOWER is over 18 years of age, and resides at 3602
Shadewell Avenue, Pittsburgh, PA 15227.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
MICHAEL T. MCKEEVER
December 29, 2009

Before me this )...4 day
Of~
Notary u .
NOTARIAL SEAL
BARBARA L HAND, Notary Public
My Commission Expires June 19,2010
EXHIBIT
IMq- 16
OCl- 00223\
CITJMORTGAGE INC.
Plaintiff CIVIL DIVISION
vs.
NO.: MG-09-002231
ALISON R. LOWER
Defendant(s)
AFFIDAVIT OF COMPLIANCE WJTH ACT 6 OF 1974,41 P.S. 101, ET.SEO.

AND ACT 91 OF 1983
)
) SS:
)
Commonwealth, personally appeared Michael T. McKeever, attorney for the Plaintiff, who being duly
sworn according to law deposes and says that on, Defendant(s) was/were mailed a Notice(s) of
SWORN TO AND SUBSCRIBED BEFORE
~rnJS&L~ ,2009,
Notary Pub ic
EXHIBiT
11
M6- 09- 00223i
Attorney I.D. #56129 A TIORNEY FOR PLAINTIFF
701 Market Street
..IPMORGAN CHASE BANK, N.A, AS ACQUIRER OF CERTAIN

ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK
FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION
ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK,
FA
Vs. No. MG-09-003126
CHARLES M. MORGAN ALLEGHENY COUNTY

VERIFICATION OF NON-MIUTARY SERVICE
amended.
(b) that defendant CHARLES M. MORGAN is over 18 years of age, and resides
at 1115 Bakerstown Road, Tarentum, PA 15084.
(c) that defendant, CHARLES M. MORGAN is over 18 years of age, and resides at 1115
Bakerstown Road, Tarentum, PA 15084.
falSification to authorities.
By:
GOLDBECK MCCAFFERTY & MCKEEVER
Michael McKeever Pa. ID 56129
Gary McCafferty Pa. ID 42386
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Attorneys for Plaintiff

January 19, 2010 COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
BARBARA L. HAND, Notary Public
City of Phllade!phla, Phlla. County
Swom to and subscribed My Comml88ion Expires June 19, 2010
Before me thisL. ( day
of ~2010
Notary Public
EXHIBIT
IM61-0G1-IS003/26
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
Counseling Agency.
BY:---,tVr~'b~a""","",1~_Q------,1----1'\~
'Cj~LQJ"",-"",l~~~__
GOLDBECK McCAWERTY &McKEEVER
A TIORNEY FOR PLAINTIFF
EXHIBIT
J
i I Cl
M - Oq - 003150
VERIFICATION
Michael T. McKeever, Esquire, hereby states that he is

attorney for PLAINTIFF in this matter, that Plaintiff is outside
the jurisdiction of the Court and/or the Verification could not be

obtained wi thin the time allowed for the filing of the pleading
that he is authorized to make this verification pursuant to
Pa.R.C.P 1024 (c) and that the statements made in the foregoing
pleading in the Civil Action in Mortgage Foreclosure are based
upon the information supplied by Plaintiff and are true and

correct to the best of his knowledge, information and belief.
Furthermore, it is the undersigned's intention to substitute a
verification from Plaintiff as soon as it is received by counsel.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
\''d -to' OJ
\1~QJD1 UQj~
Date:
Michael T. McKeever, Esquire

PA 1. D. #56129
#91461FC THOMAS DONALD SISCO

8 Monte Carlo Drive Pittsburgh, PA 15239
EXHIBIT
i 20
ME/-OC! -003150
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge oftheir personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$170,330.38,
By:~d 1· MC/~l~
By: MICHAEL T. McKEEVER, ESQUIRE
ATTORNEY FOR PLAfNTIFF
EXHIBIT
i
I 2\
Mq-OQ- 00 3114
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of$106,814.63,
together with interest at the rate of$15.09, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the tenus of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
By: GOLDB~~~@}F~EJryW.~~
A ITORNEY FOR PLAINTIFF
EXHIBIT
i-a 22
-----::-
M -0£1-005204
Attorney I.D. #56129 ATTORNEY FOR PLAINTIFF
701 Market Street
CITIMORTGAGE, INC. S/B/M ABN AMRO MORTGAGE GROUP,

INC.
Vs. No. MG-09-003204
JAMES M. BOYLE JR.

DIANE J. SCHMIDT ALLEGHENY COUNTY
VERIFICATION OF NON-MILITARY SERVICE
amended.
(b) that defendant JAMES M. BOYLE JR. is over 18 years of age, and resides at
3105 Deerwood Drive, Allison Park, PA 15101.
(c) that defendant, DIANE J. SCHMIDT is over 18 years of age, and resides at 3105
Deerwood Drive, Allison Park, PA 15101.
falsification to authorities.
BY: TINAMARIEfx1Cht +h
February 3, 2010
Swom to and SUbsclibed NOTARIAL SEAL
Before me this ~ day BARBARA L. HAND, Notary Public
My Commission Expire~ June 1~010
of --""'='~----7"'---
,2010
EXHIBIT
I Z3
1Yt6t-OQ-0032.04-
BY: Michae1 T. McKeever, Esquire
Attorney ID.#56 129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
CITIMORTGAGE, INC. SIBIM ABN AMRO MORTGAGE
GROUP, INC., 1000 Technology Drive O'Fallon, MO, 63304
vs. Plaintiff IN THE COURT OF COMMON PLEAS
JAMES M. BOYLE JR. and DIANE J. SCHMIDT OF Allegheny COUNTY

Mortgagor(s) and Record Owner(s)
3105 Deerwood Drive Allison Park,
PA 15101 No. MG-09-003204
AFFIDAVIT
CITIMORTGAGE, INC. SIBIM ABNAMRO MORTGAGE GROUP, INC., by its specially appointed
counsel, Michael T. McKeever, represents as follows;
I. I am the attorney for and representative of Plaintiff. I am authorized to make and do make
this affidavit on behalf of Plaintiff; and that the facts set are true and correct to the best of my
knowledge, infonnation and belief.
2. I collected $0.00 towards my client's debt.
EXHIBIT
I 24
Mq- Oq -003204-
GOLDBECK McCAFFERTY &
McKEEVER
BY: Michael T. McKeever
Attorney 1.0.#56129
701 Market Street
Philadelphia, PA ]9106
215-825~6320
ClTlMORTGAGE, ]NC. IN THE COURT OF COMMON PLEAS

1000 Technology Drive
O'Fallon, MO 63368 of Allegheny County
Plaintiff
vs. CNIL ACTION ~ LAw
EOWARD M. TURNER JR.

Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FoREcLOSURE
)0110 Pearl Road Tenn

Pittsburgh, PA 15235 No. MG-IO-000405
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
ClTlMORTGAGE, ]NC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire,
sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the
real property iocated at:
10110 Pearl Road

l.Name and address ofOwner(s) or Reputed Owner(s):

10110 Pearl Road
2. Name and address of Defendant(s) in the judgment: ~_1111!!1~~~_""

EXHIBIT
10110 Pearl Road
Pittsburgh, PA 15235 2.5
M -/0 - 000405
3. Name and last known address of every judgment creditor whose judgment is a record lien on the prOperty to be
sold:
PA OEPART11ENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement

Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
DOMEsnc RELAnONS OF ALLEGHENY COUNTY I '

440 Ross Street II
Pittsburgh, PA 15219 I
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the
property which may be affected by the sale.
TENANTS/OCCUPANTS
10110 Pear] Road
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are true and correct to the best of my personal I
knowledge or in~onnation and. belief. I understan~ that. false statem~~ts herein are made subject to the penalties ofI
18 Pa. C.S. SectIon 4904 relatmg to unsworn falSification to authontles. ; ,
i
DATED: June 15,2010 !
BY: ERIC KEENAN I
Legal Secretary

me this ~Qj~ __
bTH OF PENNSYLVANIA
NOTARIAl. SEAL
ANTONIETTE M. SLACK. Notary Public
City of Philadelphia. Phlla. County
My Commission Expires June 27. 2010
McKEEVER
Attorney I.D.#56129
701 Market Street
215-825-6320
DEUTSCHE BANK NATIONAL TRUST IN THE COURT OF COMMON PLEAS

COMPANY, AS TRUSTEE FOR THE
CERTlFICATEHOLDERS OF SOUNDVIEW of Allegheny CountY
HOME LOAN TRUST 2006-0PT5, ASSET-
BACKED CERTlFICATES, SERIES 2006-OPT5
4650 Regent Blvd CNILACTION -LAW
Irving, TX 75063
Plaintiff
ACTION OF MORTGAGE FORECLOSURE
vs.
Tenn
KARILEMP No. MG-1O-000406
MICHAEL LEMP
Mortgagor(s) and Record Owner(s)
3735 Oakton Road

Defendant(s)
SUPPLEMENTAL AFFIDA VIT PURSUANT TO RUl.E 3129
DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR THE

CERTlFICATEHOLDERS OF SOUNDVIEW HOME LOAN TRUST 2006-0PT5, ASSET-BACKED
CERTlFICATES, SERIES 2006-0PT5, Plaintiff in the above action, by its attorney, Michael T. McKeever,
Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following infonnation
concerning the real property located at:
3735 Oakton Road

KARILEMP
3735 Oakton Road
EXHIBIT
MICHAEL LEMP
3735 Oakton Road i 26
Pittsburgh, PA 15227 Mq-IO 000406
2. Name and address ofDefendant(s) in the judgment:
KARlLEMP
3735 Oakton Road
MICHAEL LEMP
3735 Oakton Road
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF ALLEGHENY COUNTY

440 Ross Street
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement

Health and Welfare Bldg. - Room 432 '
P.O. Box 2675
MICHAEL LEMP
3735 OAKTON ROAD
PITTSBURGH, PA 15227-3573
TENANTS/OCCUP ANTS
3735 Oakton Road
Pittsburgh, PA ] 5227
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or infonnation and belief. I understand that fa1se statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: August 23,2010
GOLDBEC . McCAFFERTY & McKEEVER

BY: ERIC KEENAN
Legal Secretary

~3 day
Before me this
Of~,2010
Notary Public
· '

McKEEVER
Attorney 1.D.#56129
701 Market Street
215-825-6320
BAC HOl\1E LOANS SERVICING, LP FKA IN THE COURT OF COMMON PLEAS

COUNTRYWIDE HOl\1E LOANS SERVICING LP
7105 Corporate Drive of Allegheny County
PTXC-35
Plano, TX 75024
Plaintiff CIVIL ACTION - LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
TRUDYHITE
Mortgagor(s) and Record Owner(s) Tenn
No. MG-IO-001409
1928 Rhine Street
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
BAC HOME LOANS SERVICING, LP FKA COUNTRYWIDE HOME LOANS SERVICING LP,
Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as ofthe date the praecipe .
for the writ of execution was filed the following infonnation concerning the real property located at: .
1928 Rhine Street

TRUDYHlTE
311 Faber Street
2. Name and address of Defendant(s) in the judgment:
TRUDYHlTE ~----~
EXHIBIT
311 Faber Street
Pittsburgh, P A 15214 IM~-IO
21
- 00 140q
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
·. . .
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement

Health and Welfare Bldg. - Room 432
P.O. Box 2615
DOMESTIC RELATIONS OF ALLEGHENY COUNTY

440 Ross Street
TENANTS/OCCUPANTS
1928 Rhine Street
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.s. Section 4904 relating to unsworn falsification to authorities.
DATED: September 14,2010

BY: ERIC KEENAN
Legal Secretary

Before me this 15 day
of Je~r: 2010 ,....!COM~M!2!:!!!~~~~~~
~Ik~ Notary Public
VERIFICATION
I, Patrick J. Loughren, hereby verify that the avennents contained in the foregoing
Complaint in Equity are true and correct to the best of my knowledge, infonnation and belief.
I understand that the statements and avennents herein made are subject to the penalties of
18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities.
~~
Date

Loughren V Lion Et Al Complaint in Equity

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Loughren V Lion Et Al Complaint in Equity

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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

JURY TRIAL DEMANDED

KATHLEEN M. LION, et al.

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO

Lawyer Referral Service

PATRICKJ. LOUGHREN, CIVIL ACTION - EQUITY

Plaintiff, NO. GD-to

KATHLEEN M. LION, et al.

Complaint averring as follows:

Commonwealth of Pennsylvania. Plaintiff is a trial lawyer who maintains a principal place of

business at 310 Grant Street, Suite 2800, Pittsburgh, Pennsylvania 15219.

2. Kathleen M. Lion is on information and belief the Director of Human Resources

3. Defendant, Martin Bair is on information and belief the Manager of Administrative

4. Defendant, Barbaranne Groark, is on information and belief the Director of Office

Control & Training at GMM

6. Defendant, Amal Taksaoui, is on information and belief the Administrative

Services Manager of the HR Department at GMM

Referrals/Complaint department at GMM

8. Defendant, Elijah Lewis, is on information and belief a member of the

Referrals/Complaint department at GMM

9. Defendant, Carol Connell, is on information and belief a supervisor In the

Referrals/Complaint department at GMM

10. Defendant, Jessica Cartagena, is on information and belief a member of the

Referrals/Complaint department at GMM

11. Defendant, Jaclyn Jamieson, is on information and belief a member of the

Referrals/Complaint department at GMM

12. Defendant, Nastassja Falterbauer, is on information and belief a member of the

Referrals/Complaint department at GlVIM

13. Defendant, Eileen O'Brien, IS on information and belief a member of the

Referrals/Complaint department at GMM

14. Defendant, Lisa Soda, is on information and belief a Supervisor of the

Referrals/Complaint department at GMM

15. Defendant, Nancy Schmehl, IS on information and belief a member of the

Referrals/Complaint department at GMM

Referrals/Complaint department at GMM

19. Defendant, Tinamarie Boschetti, is on infonnation and belief a member of the

Judgment department at GMM

21. Defendant, Michelle Clarkson, IS on infonnation and belief a member of the

Judgment department at GMM

Service department at GMM

Service department at GMM

28. Defendant, Diana Montanez, is on infonnation and belief a member of the

Complaint, Judgment, Log In Department at GMM

Litigation Department at GMM

LitigationIREO/Title Curative Department at GMM

31. Defendant, Nancy Kelleher, is on infonnation and belief, a member of the

Litigation Department at GMM

32. Defendant, Tabitha Wilson, IS on infonnation and belief, a member of the

Litigation Department at GMM

c. The Notary Public Defendants

Public Law, 57 P.S. § § 147-168.3.

D. The Law Firm Defendant

37. Defendant GOLDBECK, MCCAFFERTY & MCKEEVER, P.e. (hereinafter

"GMM") is a professional corporation maintaining a principal place of business at Suite 5000,

Mellon Independence Center, 701 Market Street, Philadelphia, Pennsylvania 19106.

III. JURISDICTION AND VENUE

(Bankr. RD. Pa. 1981) (law).

(1955); Boggs v. Werner, 372 Pa. 312, 94 A.2d 50 (1953).

Palmer v. O'Hara, 359 Pa. 213, 58 A.2d 574 (1948)(medicine).

conduct described hereinafter in the Allegheny County.

unauthorized practice of law. Jurisdiction is invokable on the complaint of a duly licensed

A. The Unauthorized Practice of Law by Non-Lawyers Working at Goldbeck,

46. The Supreme Court in this Commonwealth is empowered by Article V, Section