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100 South Ashley Drive, Suite 1300, Tarnpa, Florida 33602

813.229.3333 I 813.229.5946 Fax I

R L' 5 ti.,r E51 t-Al\

March 14,2011

Via e-mail to:

as well as via U.S. Mail

Ms. Lisa Epstein

Foreclosure Hamlet
2840 S. Ocean Blvd.
Unit 508
Palm Beach, FL 33480

Re: Cease and Desist Demand Regarding Materially False Statements

Concerning Nationwide Title Clearing, Inc., Bryan Bly, and Crystal Moore

Dear Ms. Epstein:

We are counsel to Nationwide Title Clearing, Inc. ["NTC"). I am notifying you that
your firm's website, contains materially false statements
regarding NTC, Bryan Bly, and Crystal Moore, claiming that NTC creates false documents
for financial institutions that are subsequently submitted to courts in mortgage foreclosure
proceedings. More specifically, your website contains the following postings which are
materially false and misleading:

1. On November 77,201,0, your site states:

MISSION CRITICAL - H.R. 3803 Needs Congressional

Attention: Insist Upon a Congressional Vote to UPHOLD
ttre Presidential Veto:
A feffow Haml-et Member asked me to post the IMPORTANT
information below.


Dear Congressman

Since the "robo-signing" sLory was macie public on

September 2Q, 2010, it has become cfear that the mortgage
meltdown, the housing crisis, foreclosuregate - cafl it
Ms. Lisa Epstein
Page 2

what you will - involves numerous layers of impropriety,

ftoutirrg of long
lenders and loan servicers,

f want to point out Lo you that within the deposition of

Crystal MOORE (Part 3), as posted on YouTube, there are
a series of questions pertaining to Crystaf MOORE's
digital sj-gnature of documents.
While the ENTIRETY of this series of Video depositions
i-s COMPELLING, I woul-d encourage you to REVIEW the video
deposition Part 3 and in particufar the portion between
9:04 mins (-10:46:30) and 11:30 mins (-10:49:15)
Crystal Moore Deposition Part 3.np4
http : / /www. youtube. com/watch?v=N5Pl{oklfdgE

It is readily apparent to those who are knowledgeabfe

about foreclosure mill practices WHY this bil-l is being
pushed by the Banksters. PERIIAPS HEARING THE CRIMINAL

This posting falsely accuses Crystal Moore of being a "criminal perpetrator" when
she executes documents on behalf of NTC. The posting must be removed immediately. In
addition, on November L9, 20L0, Sarasota Circuit Judge Rick DeFuria entered a temporary
and mandatory injunction against Christopher Forrest and The Forrest Law Firm, and all
persons acting in concert with either, enjoining those individuals from "posting, publishing,
disseminating, or maintaining materials from the video depositions of [Bryan Bly, Crystal
Moore, and Dhurata Doko] until further order by this Court." A copy of |udge DeFuria's
injunction is enclosed for your review.

Your November t7,2070, post may not refer to Ms. Moore's video testimony and
you must immediately remove all links or references to Mr. BIy, Ms. Moore, or Ms. Doko on
your website, www.foreclos

2. Your site's November 8,20L0, post contains a post with the heading
"Mortgage Fraud" that reads as follows:
Ms. Lisa Epstein
March \4,2077
Page 3

Featuring WiIdIy Productive Robosigners Bryan Bly of

Document Solutions Company, Nationwj-de Tit1e Clearing
Mortgage Fraud
Bryan Bly
Nationwide Title Clearing

Action Date: llovember 8, 2070

Location: PaIm Harbor, FL
The video-taped depositions of employees of Nationwide
Title Clearing in Palm Harbor, Florida, were made
available on the website Stop Foreclosure Fraud. The
deposition of Bryan B1y is particularLy startling and
straiqhtforward. Bryan B1y signed documents and witnessed
or notarized other documents. Bly testified that he did
not witness the signatures he notarized. B1y signed in
batches of 200. Bly signed app::oximately 5,000 mortqage
assig,nments each day. Bly also signed as an officer of
many lenders. Bly sigrned as an officer of over 20 banks
and mortgage companies. His supervisors told him there
were corporat.e resolutions authorizing him Lo sign using
these titles. Bly had no knowledqe of the information on
the documents. Bly did not know what was meant by a
mortqaqe assignment or an attorney-in-fact although he
signed mortqage assignments as an officer of Citl
Financial as attorney-in-fact for Argent Mortqage. He did
not verify any information other than to make sure co-
employees had signed their names so there were no bl-ank
lines on the documents. He has done this work for
approximately 10 years. One of the titles not discussed
in the deposit ion, but used on Lens of thousands of
mortg,age assignments signed by B1y was Attorney-In-Fact,
Federal Deposit Tnsurance Corporation, as Receiver for
IndyMac Federal Bank FSB, successor to TndyMac Mortgaqe
Holdings, fnc. Bly continued to sign as Attorney-In-Fact
for the FDIC as recently as.Tune 25, 2010. A copy of an
assignment signed by B1y as Attorney-In-Fact for the FDIC
is available in the "Pleadings" section of Fraud Digest.
Lynn Szymoniak, Esq
Fraud Diqest
Ms. Lisa Epstein
March 'J,4,20'J.'J.
Page 4

Not only does your post summarize Mr. Bly's deposition post which is in violation of
fudge DeFuria's injunction as stated above, your website falsely implies that it was
improper for Mr. Bly to sign numerous mortgage assignments each day as an officer of over
20 banks and mortgage companies, even though he was told there were corporate
resolutions from those companies authorizing him to sign as an officer of those banks and
mortgage companies. You go on to falsely imply that Mr. Bly was guilty of wrongful
conduct because he did not read the assignments before signing them and had no
knowledge of their contents. All of this of course, is posted under the heading "Mortgage

As I am sure you know by now, NTC has duly-executed resolutions or powers of

attorney for the financial institutions on whose behalf Mr. Bly executed the assignments.
Assignments simply need to be executed; the signer is not required to read them before
signing, and your posts suggest otherwise. It is false and misleading and must be removed

3. Your post of October LI,2010, entitled "Pigs Ass" wrongfully implies that any
documents created by NTC, Bryan BIy, or Crystal Moore should be presumed to be
false. The post states:

Pigs Ass: Damn! Paid off note to the tune of $L72,000 to

the wrong party!
o Posted by L on October 11, 201,0 at 11:30pm
o View L's bloq
From Urban Dictionary: The term "pigs ass" is used in
many situations. It is most commonly used whe4 €aucarrc
claims somethinq is not true.
Let's just break down how it happens over and over.
Here's the morLgage.

2006 took out $172,000 mortqage with NovasLar (MERS

mortgage .sure, sure, we just- KNOW this is trouble
already) Novastar Mort 172K.pql.L
Here's the satisfactlon of mortgage.
20l.0 Sacisfaction of Mortgage executed by MERS as
nominee for Novastar who is st-ated Lo be t-he owner and
Ms. Lisa Epstein
Page 5

holder (eeee qads, it's the robo-pair Brren 81ry and

Crystal Moore from Nationwide Title. I guess Brian B1y
of MERS flew from Texas to Fforida to have this document
notari-zed? ) MERS Novastar saL - nclf

Nationwide appears to have had sold this mortgage to Jp

Morgan Chase at some point.

Presumption of Farsity should be the new code word when

viewing any of these dr:bious documenE.
The statement claiming that documents created by NTC, Bryan Bly or Crystal Moore,
should be presumed by others to be false is materially false and misleading, as well as
Iegally actionable. This post must be removed immediately.

4. Your post dated September L4,201.0, and entitled "Anthology of the

Works of a Prolific Robosigner: Jeffrey Stephan of GMAC" states

Many other mortgaqe servicing companies and foreclosure
firms have filed thousands of other wort.hfess, unfounded

Will the same judges who accepted thousands of these

worthless Affidavits now belreve the allegrations that the
foreclosure law firms acted in grood faith when they
presented these documents to Courts?

Brvan B1v, Crwstal Moore and the

professional siqners may finally be heldother
accountable for
their sworn false stat.ements.
5. Your post of fune 29,20'1,0, entitled "Comments for: Lynn Szmoniak"
Ms. Lisa Epstein
March 1.4,2011
Page 6

w rm in mediation, their asking for a hardship Jetter...go

figure, f stated we didn, t have a hardship...Judge said,
"ff you don,t pfay the game, then you wiff .Iose your
home"...Got to fove '-rustice! Ma). r ask if lrou have anltthing
on Nationwide Tit_Ie Cfearino with two of their
empfovees...Fraudufent sioner and notarv whose names are
Maru Jo McGo*an as vp fot seueraf banks and MERS...her
notarlr is a Mexican citizen here on a visa Maria Lenor
Gerhofdt- The fraud here in Maine is comina out of
PineLLas countv, my home shoufd be down there witn L...fof
Thanks again Lynn for a-r-t you do helping to expose the
fraud and giving 1:eoTsJe like mlzseJf vafuabLe
Added by KT at 1: 44 pm on .fune 23, 2OIO

The statement that Mary Jo McGowan of NTC is a "fraudulent signer" and that the
"fraud . . . is coming out of Pinellas Counl5/" (where NTC has its offices) is false and
materially misleading. It must be removed immediately.

Complete copies of these website posts are attached hereto for your review.

As I am sure you know from NTC's suit against Matthew Weidner

fwho also posted
materially misleading information on his website, but has since retracted the posts ind
apologized for them), NTC has duly-executed corporate resolutions or po*"ri of attorney
for the financial institutions on whose behalf Mr. Bly, Ms. Moore and its other employees
execute assignments. Most of those resolutions or powers of attorney are confidential, but
I am attaching one from Citi Residential Lending, Inc., that is in the public record and that is
similar to others that NTC has obtained for its business purposes. You will note that the
resolution states, inter alia:

RESOLVED, thal each of the employees of Nationwide

Title Clearinq, Inc. 1"NTC") listed below be, and they
hereby are, named and appointed as a vice president and
Assistant secretary of the Corporation solely for the
purpose of acting as duly aut.horized signatories on it.s
behalf, such that any of the listed personnel fldy,
so1ely in their capacity as authorized signatories,
execute any and all reasonable and necessary documents
required in connection with processing the Assig-nments
and Releases;
Bryan Bly
Crystal Moore
Ms. Lisa Epstein
March L4,201.L

Please go to www.nwtc. com/aboutf lrAQ.html and

can-go-a-long-way-for-the-media and learn the true facts concerning NTC and Mr. Bly.

I advise you that there is no exceptioin under the defamation law for "republishing"
posts from other internet sites. The law in Florida is that repetition of libelous material ii
actionable, even if the "republisher" refuses to vouch for its veracity. See Lewis v. Evens,
406 So. 2d 489 [Fla. 2d DCA 198U. Moreover, defamatory comments are actionable even if
made in internet "chat rooms," See Becker v. Hooshmand, B4I So. 2d 561
[Fla. 4th DCA

You must remove all references to Mr. Bly, Ms. Moore, NTC, or any of its other
employees within five [5J days of the date of the letter and cease and desist making any
false statements about Mr. Bly, NTC, or its employees, whether on the Internet or

To the extent that you contend that you published these comments in good faith; or
that their falsity was within the protective mechanism outlined in Section 770.02, Florida
statutes fwhich NTC disputesJ, NTC, Mr. Bly, Ms. Moore, Ms. Doko and Ms. McGowan hereby
demand that a full and fair correction, apology, or retraction be made as provided by law.

If you do not remove these false statements and cease your wrongful activity, NTC
intends to avail itself of all available legal remedies against you and anyone else associated
with www. foreclosu

You have been duly notified. Govern yourself accordingly.

Very truly yours,

Grnruru Resuussnru Focanry & Hooxn& p.A.

"c(ruwuS e&."-
Michael B. Colgan



04437-00100 62314O v2