Professional Documents
Culture Documents
V.
FRANCISCO PLAZA and
CHRISTINE CHAVEZ PLAZA
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Defendants.
I.
This matter is a Texas Rules of Civil Procedure "Expedited Foreclosure ". It is
currently set for the homeowner's "Motion for New Trial" hearing on May 28,2014 . The
basis of the new trial request is newly-acquired, whistleblower-type evidence that
unequivocally does , as follows :
II.
homeowner that a loan modification was being considered i.e., foreclosure would
not take place;
4. Reflects that in the past defendant's counsel made affirmative declarations to
homeowner that loss mitigation procedures were underway i.e., foreclosure would
not take place.
III.
Further, the evidence demonstrates that the plaintiffs "Business Records Affidavit"
and other similar records (and the accompanying testimony thereto) is false , misleading
and/or simply invalid. Defense counsel made vigorous evidentiary objections (both on the
record and off). Plaintiff, nevertheless, introduced false, incorrect or misleading evidence.
This appears to be aggravated perjury made by, and clearly to the benefit to, JP Morgan
Chase, NA. This concern was previously raised by defense counsel (see attached).
IV.
V.
Therefore, additional time is necessary. The defendant's respectfully ask for this
continuance as it is made in good faith and with a reasonable basis. This continuance is
not sought for the purposes of delay but so that justice may be served.
Rich rd A. Roman
505 East Rio Grande
EI Paso, Texas 79902
Tel: (915) 351-2679
Fax:(915 ) 351-6754
State Bar # 00794909
CERTIFICATE OF SERVICE
On this 1i...1L day of May, 2014 a true and correct copy of this i
Rachel Donnelly, Esq., via regular mail, email transmission an f
STATE OF TEXAS
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COUNTY OF EL PASO
VERIFICATION
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March 12.2016
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Ms. Donnelly:
Thanks . I believe the court will certainly want to be apprised of
the new evidence which I believe will invalidate your order.
Richard A. Roman, Esq.
Former JUdge of the 346th District Court
505 East Rio Grande
EI Paso , Texas 79902
(915 )351-267
(915) 351- 54 fax
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trial,
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0 281-925-5253
f 281-925-5353
by Doranne Jacobso n on
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C ONFIDENnA UlY NOl1C E: The inf orm ati on cont:2i'l"ted in t his electroni c mail transmis sion is cont identrel. This traesm tss ton may also
De legalty privileged work produc t or proprie tary lntormeuon , This inrcrrna liotl is inlend ed f or (he exclo eiv e us e of th e acdreasee. 11
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5116/2014
casesearch.epcounty.corrVPublicAccess/CaseDetail.aspx?CaseID=4682287
REGISTER OF ACTIONS
CASE
No. 2013DCV253I
PARTY INFORMATlO"
Lead Attorneys
Defendant
Defendant
Defendant
PLAZA, FRANCISCO
Pro Se
Plaintiff
RACHR DONNB-L Y
Retain ed
281-925-5200(W}
EVENTS
&0
DISPOSlll0 NS
04/2512014 Order for Foreclosure (Judicial Officer: Kurita, M. Sue)
Judgrrent
Awarded To: JPII/rORGAN CHASE BANK, NATlONAL ASSOCIATION
Awarded Against: FRANCISCO Fl..AZA, et al
Answer
Unserved
Unserved
Unserved
OCCUPANT OF THEffiOPERTY
07/05/2013
07105/2013
07/11/2013
08/16/2013
08/16f2013
08/16f2013
08116/2013
08116/2013
08/27/2013
08127/2013
08128/2013
091171201 3
11/15/2013
02125/2014
02125f2014
Unserved
Unserved
Unserved
Doc ID# 4
Doc 100 6
04J25J2014
04/2512014
04/25/2014
~ 05/1 2/20 1 4
Doc 1D#16
Doc ID# 17
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