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1 Samuel Salmon Judge Rosanna Malouf Peterson

Roxy Salmon
2 Salmon Residence
917C Philpott Rd.
3 Colville, WA 99114
Telephone: 509-684-8841
4 Email: srslunop@gmail.com
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6 UNITED STATES DISTRICT COURT


7 EASTERN DISTRICT OF WASHINGTON
8 AT SPOKANE
9
)
10 Samuel Salmon and Roxy Salmon, )
) Case No. 2:10-CV-00446-RMP
11 Plaintiff, )
)
12 vs. ) MEMORANDUM IN SUPPORT OF
) MOTION TO DISQUALIFY
13 Bank of America, Recontrust, MERS, ) COUNSEL
)
14 Merscorp Inc., )
)
15 Defendant )
16

17 UNQUALIFIED THREAT
18 1. Lane Powell in a letter Exhibit (K) issued a stipulation and an “ORDER
19 CANCELLENG LIS PENDENS” without processing the paperwork
20 correctly through the court system. The letter threatened the removal of the
21 Salmons LIS PENDENS filed at the Stevens County Recorders Office,
22 incorrectly citing RCW 4.28.328 and Bramall v. Wells. The letter included
23 an extended threat that if we did not agree and sign the stipulation and send
24 it back with a prepaid envelope, Bank of America Corporation would file
25 an action removing the Lis pendens and charging the Salmons to do so.

Salmon Residence
Memorandum for Disqualifying Counsel - 1 917C Philpott Rd.
Case No. 2:10-CV-00446-RMP Colville, WA 99114
Telephone: 509-684-8841
1 IS BANK OF AMERICA A CLAIMANT?
2 2. Bank of America is a claimant in this wrongful foreclosure action. I
3 never thought I would have to state this, but there it is.
4 a. Bank of America in its letter Exhibit (G) boldly claims its position in
5 regards to the Loan on the Salmons property by issuing a forged
6 “NOTE” with a “Payoff Demand Statement”, and claiming servicing
7 rights through their internal records and MERS. FURTHERMORE,
8 Bank of America is the sole owner and controller of BAC Home
9 loans servicing LP FKA Country wide home Loans Servicing LP, or
10 (BAC).
11 b. Although Bank of America has not produced any “proof of loan”,
12 their illegitimate claim on the Salmons property is obviously why
13 they are listed on the Lis pendens.
14 QUESTIONABLE MOTIVES
15 3. The intent behind such a demand is questionable at best. The letter from
16 Lane Powell was understood by the Salmons as a threat with a penalty for
17 inaction. This is not the kind of unprofessional conduct the Salmons would
18 like to be subjected to and sites RPC 8.4 (c)(d)(e), as the action is deceitful
19 in misusing the RCW to coerce the Salmons into believing, and acting
20 upon their claim. Then issuing an order with the judges name ready for a
21 signature without submitting the documents properly through the clerk’s
22 office, thereby portraying that Judge Rosanna Malouf Peterson is perceived
23 to be an informed party of this action.
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Salmon Residence
Memorandum for Disqualifying Counsel - 2 917C Philpott Rd.
Case No. 2:10-CV-00446-RMP Colville, WA 99114
Telephone: 509-684-8841
1 REQUEST
2 4. The Salmons do not understand why this was even made into an issue and
3 would request the court Disqualify Lane Powell for such an act of coercion
4 granting payment of just costs for the Salmons having to take the time to
5 answer such a demand.
6 DECLARATION
7 I, Samuel Salmon hereby declare under penalty of perjury under the laws of the
8 United States and the State of Washington that on Monday, January 24, 2011, all
9 undersigned statements, and the attached letter from Lane Powell attached as
10 Exhibit (K) to be true and correct, and I, Samuel Salmon am competent to state
11 the matters set forth herein, that the contents are true, correct, complete, and
12 certain, admissible as evidence, and reasonable and just in accordance with
13 Affiant’s best firsthand knowledge and understanding.
14
CERTIFICATE OF SERVICE
15
I hereby certify that on Monday, January 24, 2011, I filed the foregoing document
16

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with the Clerk of Court. I certify that a true and correct copy of said Motion was

18 sent to all alleged case participants in the following manner: CM/ECF.


19
Dated this Monday, January 24, 2011
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Salmon Residence
Memorandum for Disqualifying Counsel - 3 917C Philpott Rd.
Case No. 2:10-CV-00446-RMP Colville, WA 99114
Telephone: 509-684-8841
s/ Samuel Salmon
1 Salmon Residence
917C Philpott Rd.
2 Colville, WA 99114
Samuel Salmon
3 Roxy Salmon
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Salmon Residence
Memorandum for Disqualifying Counsel - 4 917C Philpott Rd.
Case No. 2:10-CV-00446-RMP Colville, WA 99114
Telephone: 509-684-8841

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