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DISTRICT COURT, COUNTY OF JEFFERSON

STATE OF COLORADO
Court Address: 100 Jefferson County Parkway
Golden, CO 80401
Court Telephone: 303-271-6145

Plaintiff: LANCE CASSINO


v.

Defendants: JPMORGAN CHASE BANK, NATIONAL


ASSOCIATION,
CYNTHIA RILEY-GRABER,
JOHN DOES 1-3. COURT USE ONLY

Attorney for Defendant: Case No.:


Lance Cassino Pro Se
until attorney retained COMPLAINT FOR
POB 1050 QUIET TITLE
Conifer, CO 80433
303-838-0221
lancecassino@msn.com

COMPLAINT FOR QUIET TITLE UNDER RULE 105

COMES NOW Plaintiff, Pro Se and with his Complaint for Quiet Title under Rule 105

against the Defendant/s and alleges:

NATURE OF THE CASE

Defendant JPMORGAN CHASE BANK, NATIONAL ASSOCIATION (hereinafter

CHASE) alleges that it is the Owner of Plaintiff Lance Cassinos (hereinafter CASSINO)

Promissory Note (Note) by virtue of Assignment of the Note to Washington Mutual Bank,

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N.A. and that Banks subsequent acquisition by Defendant pursuant to a Purchase Agreement

executed with the FDIC. However, CHASE also has stated the exact opposite in their November

2013 settlement with the FDIC v. Chase for $13 billion, that stated clearly that CHASE was not

successor-in-interest to Washington Mutual Bank, N.A. loans and also in a deposition by

Lawrence Nardi see Exhibit A - JPMorgan Chase ADMITS not the successor in interest to

WaMu loans where Mr. Nardi testified CHASE was not successor-in-interest to Washington

Mutual Bank, N.A. loans.

Currently, the Deed of Trust securing this Note secures a 5.1 acre parcel of unimproved

ground in Jefferson County.

Throughout the proceedings of previous case number 2011CV4858, CASSINO staunchly

asserted that no other party had any ownership interest in MR. CASSINOs property.

Plaintiff also timely raised the issue of standing of Defendant in Paragraph number 21 of

his Answer in previous case number 2011CV4858.

FACTUAL BACKGROUND

Plaintiff Cassino has owned since 1999 two parcels of ground in Jefferson County,

Colorado on which sits his primary residence at 13883 South Wamblee Valley Road, Conifer CO

(the Property). Said land consists of two distinct parcels identified by one tax parcel number

with the Jefferson County Assessors office. The larger Parcel (Parcel 1) consists of 40 acres

together with Defendants home on 40 acres. The 2nd parcel (Parcel 2) consists of 5.1 acres of

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subdivided platted ground which abuts to Parcel 1. It is Parcel 2 which is currently encumbered

by the Deed of Trust.

In 2003, Defendant hired a Surveyor, Evergreen Surveying, to survey both parcels of

land, and to form a legal description which would encompass Parcel 2 together with 5 acres

within Parcel 1, and which would include Defendants home and outbuildings. This survey was

done in anticipation that upon any refinance, this new legal description could be used to

encumber only 10 acres of ground, including Defendants home, and which would provide

adequate collateral for any new loan obtained.

In September 2005, Defendant sought and received a new $200,000 loan from

Community Mortgage Group, Inc. (hereinafter CMG). This Promissory Note was subsequently

assigned, but the Note reflects two different Assignments, based on the Note and the Allonge

attached to the Note. One Assignment purported to transfer ownership of the Note to

Washington Mutual Bank. The other Assignment, shown on the Allonge to the Note, purported

to assign the Note to Union Federal Bank of Indianapolis.

At all times, up to and during the closing, Plaintiff believed that the new 10 acre legal

description for home and property would be used instead of 45 acre legal descriptions for home

and property to provide the collateral for said loan and would be reflected on the Deed of Trust.

In fact, the Deed of Trust securing the Promissory Note only encumbers the vacant 5.1

acre parcel for some nefarious and fully unknown reason. It is Plaintiffs belief and

understanding and that instead of delaying closing to do required contingency of loan secured by

10 acres not 45 acres as previous lender deed of trust those involved mortgage broker, title

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company, bank, evidently did whatever they had to do, in order to close with Cassino as CMG

went declared bankruptcy or went out of business 2-3 months or so after closing 9/26/2005.

On or about September 2011, Defendant CHASE attempted to begin foreclosure

proceedings through the Public Trustee against Plaintiff for alleged nonpayment on the

Promissory Note (the truth is due to CHASE refusing CASSINOs regular monthly payment on

1/15/2011 by phone purely in retaliation after CASSINO retained attorney Mitchell J. Stein &

Associates for either a real loan modification only if CHASE was note holder in due course -

and if not then quiet title.

Defendant CHASE then illegally arranged with Mortgage Electronic Registration

Systems, Inc. (hereinafter MERS) to convey the Deed of Trust into Defendants name and to

record such Assignment of Deed of Trust, as it is a necessary requirement of the Public Trustee

that the Deed of Trust being foreclosed upon be shown in the foreclosing partys name. It was at

that time that Defendant CHASE learned that the Deed of Trust only had the legal description for

the vacant 5.1 acre parcel and brought their now very complicated wrongful foreclosure by

fraudulent foreclosing documents action with case number 2011CV4858.

Defendant CHASE again also alleged that it is the true holder of the Promissory Note

because the Note was assigned to Washington Mutual Bank. However, Defendant has neglected

to explain the Allonge attached to said Promissory Note assigning the Note to Union Federal

Bank of Indianapolis. Further, despite requests by the Plaintiff to produce the original Note, or

evidence of the chain of Assignment showing that Chase is in fact the holder of the Promissory

Note, Chase has been unable to produce neither in previous case number 2011CV4858 and will

not be able to in this instant case. To explain this very serious problem, Defendant CHASE

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relies on 2 very different Affidavits (8 months or so apart that they somehow lost a note they

never had per FDIC v. CHASE $13 billion settlement in 2013) provided by its Document

Custody Department which states that Chase was the servicer of the Note and had custody of the

loan file.

Plaintiff in that case number 2011CV4858 filed a Motion to Dismiss under Rule 12(b)(1)

stating that CHASE did not have standing to bring the action, and that the Court did not have

subject matter jurisdiction. That Motion was pending before the Court when CHASE begged to

settle before trial that was set for 12/28/2012 and finally partially did so on March 15, 2013 see

Exhibit B - Settlement Agreement March 15, 2013 - paying $10,000 of Cassinos attorneys fees

for case number 2011CV4858.

ARGUMENTS TO BE RAISED AT QUIET TITLE TRIAL IF NEED BE

I. Did or will Defendant adequately establish that it is the true Owner of the
Promissory Note secured by the Deed of Trust?.

At the outset of the previous case, Defendant alleged that it was the holder of the Note, and

as such, claimed to have established standing to bring the action. It is the burden of the

Defendant to establish standing. Standing [is] treated as a question of subject matter jurisdiction

under subsection (b)(1). Grand Valley Citizens' Alliance v. Colo. Oil & Gas Conservation

Comm'n, __ P.3d __ (Colo. App. 2010), rev'd on other grounds, 2012 CO 52, 279 P.3d 646. It is

the Defendants burden to establish that they in fact have standing to bring this action. A

Defendant has the burden of proving that the trial court has jurisdiction to hear the case.

Pfenninger v. Exempla, Inc., 12 P.3d 830 (Colo. App. 2000). Reynolds v. State Bd. for Cmty.

Colls., 937 P.2d 774 (Colo. App. 1996). Defendant acknowledges that it cannot produce the

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original Note, and that it cannot produce a chain of evidence establishing that it is the Owner of

the Note. Plaintiff Cassinos belief whether or not CHASE was/is the Owner of the Note does

not help nor hinder Defendants burden to in fact show that it was the rightful Owner, and is

irrelevant to the discussion. Because CHASEs problem is no consideration no injury no

standing.

In addition to the circumstantial evidence provided by Defendant. CHASE offers both a

Lost Note Affidavit and a Lost Instrument Affidavit 8 months or so apart in 2012 to support

its claim that, because it has custody of the loan file, that ergo, it must be Owner of the Note. In

fact, Chases own employees, in those affidavits, have indicated that she can only attest to the

fact that she believed CHASE to be the Servicer of the loan. No statement of Ownership of the

Note can be found in the Lost Note Affidavit or the Lost Instrument Affidavit.

Defendant also pointed to the Assignment of the Deed of Trust by MERS recorded in

September 28, 2011 as evidence that it owns the Note. In Colorado, the Courts have held that

the Deed of Trust follows the Note. If Chase cannot establish that it is the true owner of the

Note, then any assignment of the Deed of Trust to Chase is void ab initio, and could in fact,

violate Colorado statutes for recording of false or misleading documents in the County recording

system under CRS 38-35-102. Further, the signing of the DOT Assignment by a Chase

employee, purporting to be an Assistant Vice President of MERS and notarized by a fellow

Chase employee is fraudulent on its face and violative of the MERS Consent to Cease and Desist

Order entered into by MERS in April 2011 with the Office of the US Currency Comptoller.

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Plaintiff Cassino believes that Defendant CHASE failed in the past case and will fail

again in this instant case to meet its burden of proof by a preponderance of the evidence present

in this complaint and exhibits, that CHASE is in fact the true owner of the Promissory Note.

II. Is the failure of Defendant to name indispensable parties to the previous action
should have been grounds, in and of itself, for dismissal with prejudice of the
previous action?.

Defendant acknowledges in the previous case number 2011CV4858 by its own Exhibit

for the Promissory Note, that certain parties may have an equitable interest in the quiet title

action that it sought. In particular, that party is Union Federal Bank of Indianapolis (Union

Federal), who was purportedly assigned the Ownership of the Note by virtue of the Allonge

signed by Community Mortgage Lending.

Union Federal no longer exists, as it was acquired by Sky Bank in 2008. Sky Bank no longer

exists, as it was acquired by merger with First National Bank of Tennessee. It should be

noted that none of these banks failed, and each was acquired in an arms length purchase

transaction.

Defendant CHASE knew, or should have known, that each of the above-named banks

had or could have an equitable claim of interest in the Promissory Note, and hence the Deed

of Trust. Defendants failure to name such parties precluded the Court from its ability to

render a verdict in that case number 2011CV4858 - affecting the title and all parties in the

case, and hence should have been dismissed with prejudice on those grounds alone instead

of Plaintiff being conned and sandbagged by agreeing to CHASEs begging for a partial

Settlement Agreement before trial by jury that was set for 12/28/2012.

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III. Does Chases request for an Assignment of the Deed of Trust, knowing that it was
not in possession of the Promissory Note, and the signing of such Assignment by its own
employee, notarization of such document by its own employee and recording of such
document in the public records constitute grounds to invoke the unclean hands
doctrine

The doctrine of unclean hands is an equitable defense to proceedings in equity and is

premised on the theory that one who requests equity must do so with clean hands. Wilson v.

Prentiss, 140 P.3d 288 (Colo.App.2006). Thus, a court will not consider a request for equitable

relief under circumstances where the acts of the party requesting equitable relief offend the sense

of equity to which the party appeals.

Defendant recorded the fraudulent Notice of Election and Demand For Sale on 3/17/2011

knowing that the public, the court and the Public Trustee would rely on the truth of the matters

contained therein. Defendant knew, or should have known, that in fact it had no evidence that it

was the Owner of the Note, or agent for it.

Defendant also recorded the fraudulent Corporate Deed of Trust Assignment knowing

that the public, the court and the Public Trustee would rely on the truth of the matters contained

therein. Defendant knew, or should have known, that in fact it had no evidence that it was the

Owner of the Note, and hence the Deed of Trust being assigned.

Defendant then further served fraud upon the court and trustee with 2 false and fraudulent

affidavits of lost instrument or note knowing that the public, the court and the Public Trustee

would rely on the truth of the matters contained therein.

IV. PARTIES

1. Plaintiff is a resident of Jefferson County, Colorado with legal title to the property

at 13883 S. Wamblee Valley Road, Conifer, Colorado 80433 containing 2 parcels since 1999

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see Exhibit C - Personal Representative's Deed recorded 7/19/1999 conveying title to 40 acre

parcel with home to Lance R. Cassino and Exhibit D - Personal Representative's Deed recorded

12/16/1999 conveying title to 5.1 vacant acre parcel to Lance R. Cassino.

2. Defendant JPMorgan Chase Bank, National Association, (hereinafter CHASE)

is a Delaware corporation doing business in Colorado and is a debt collector violating FDCPA

1692f(6)(A) see Exhibit E - Chase Mortgage Loan Statement dated June 16, 2017.

3. Defendant Cynthia Riley-Graber (hereinafter Cynthia) is an attorney

representing CHASE employed by Bryan Cave LLC. Cynthia is named as a Defendant because it

is Plaintiffs belief and understanding that despite her knowing Plaintiffs allegations about the 4

fraudulent foreclosing documents in previous Case number 2011CV4858 and, in this instant

case, may still ignore those claims that have merit and serve again upon the court and trustee

those very same documents in another attempt to prove injury or standing - that are known to be

fraudulent or that are now void by operation of law due to effective TILA rescission dated

January 30, 2015. Those documents are: Notice of Election and Demand for Sale - filed

3/17/2011; Corporate Assignment of Deed of Trust dated 9/21/2011 - 6 months plus after

claiming "standing" as PETE (person entitled to enforce); Affidavit of Lost Note dated

4/24/2012 by Ashley Jordan; Affidavit of Lost Instrument dated 12/1/2012 by Serina Lee,

Promissory Note and Deed of Trust. Regarding the effective TILA rescission dated January 30,

2015 see Exhibit F Rescission Letter dated January 30, 2015 recorded in the Jefferson County

land records. Cynthia became full aware of most of the white collar criminal allegations made in

this complaint when she was tasked by Chase and Bryan Cave LLC to reply to a letter by

Cassino sent May 33, 2016 to Mr. Jamie Dimon offering to settle this stalemate for $10,000 see

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Exhibit G - Letter to Mr. Jamie Dimon dated May 3, 2016 (includes Cynthia Lowery-

Graber letter reply for Chase/Mr. Dimon dated July 7, 2016) offering an out of court

settlement opportunity to end 6 years plus stalemate.

V. JURISDICTION AND VENUE

4. This Court has jurisdiction over the parties to and subject matter of this

Complaint.

5. Venue is proper in this Court pursuant to C.R.C.P. 98, as this matter concerns title

to real property located in Jefferson County, Colorado.

VI. GENERAL AVERMENTS

6. On January 5. 2012, Plaintiff Lance Cassino (hereinafter MR. CASSINO)

received a Complaint (filed November 16, 2011) from CHASE, giving notice of a foreclosure

action (Case No.: 2011CV4858) on MR. CASSINOs property at 13883 S. Wamblee Valley

Road, Conifer, Colorado 80433 in Jefferson County, Colorado (hereinafter property).

7. The property is and was subject to a deed of trust to the public trustee allegedly

for the benefit of Community Mortgage Group, Inc., to secure a promissory note to Community

Mortgage Group, Inc., dated September 26, 2005, in the original principal amount of $200,000.

8. CHASE purported to be the successor in interest to Community Mortgage Group,

Inc. through Washington Mutual Bank through Chase through JPMorgan).

9. The original promissory note has never been indorsed from the original payee to

CHASE.

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10. CHASE was not the owner of the subject promissory note.

11. On November 16, 2011 CHASE filed a complaint to reform the deed of trust and

then foreclose with Jefferson County District Court, Case No. 2011CV4858.

12. On March 15, 2013 CHASE executed a Settlement Agreement with Cassino

paying Cassino $10,000 for his attorney fees to avoid trial by jury December 28, 2012 due their 4

fraudulent foreclosing documents - especially their false and fraudulent Corporate Assignment

of Deed of Trust (a MERS/CHASE self-assignment) recorded in the land records September 28,

2011 a felony per Colorado Revised Statutes Title 18 Criminal Code 18-5-114 Offering a

false instrument for recording. Cassinos counter claim was quiet title.

13. CHASE deliberately misled this Court in previous case 2011CV4858 by fraudulently

asserting that they were the real party in interest, the sole owner and beneficiary of the loan MR.

CASSINO originally took out with Community Mortgage Group, Inc., on or about September

26, 2005. Starting with claiming standing as PETE with a false and fraudulent Notice of Election

and Demand for Sale - recorded 3/17/2011 see Exhibit H - Notice of Election and Demand for

Sale. Which was proven false and fraudulent by Chase themselves by recording over 6 months

later see Exhibit I - Corporate Assignment of Deed of Trust dated 9/21/2011 another false

and fraudulent document served upon the court in that case. And to make white collar crime

matters worse, their 2 other false and fraudulent foreclosing documents: Affidavit of Lost Note

dated 4/24/2012 by Ashley Jordan and Affidavit of Lost Instrument dated 12/1/2012 by Serina

Lee (see Exhibit J - Forensic Examination Report dated June 15, 2017 on Corporate Assignment

of Deed of Trust dated 9/21/2011 - 19 pages and Exhibit K - Forensic Examination Report dated

March 30, 2017 on Affidavit of Lost Note dated 4/24/2012 and Affidavit of Lost Instrument

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dated 12/13/2012 - 26 pages). The assignment and the 2 affidavits are counterfeit not genuine per

expert witness and document examiner Mr. Gary Michaels photoshopped forgeries. Applicable

authority allowing challenges to Void, Voidable and Fraudulently recorded mortgage documents

affecting chain of title: 1. Colo.Rev.Stat. 38-35-204. Order to show cause (Spurious Lien); 2.

Colo.Rev.Stat. 38-35-201, a spurious lien is a lien that [i]s not created, suffered, assumed or

agreed to by the owner of the property it purports to encumber.; Colo.Rev.Stat. 18-5-102

(1)(c) Forgery, Written Instrument; 4. A common law right to cancellation of written instruments

exists. See Hampton v. Tri-State Finance Corp., 30 Colo.App. 420, 425 (Colo 1972). Statute

Description and Actionability: 1. Colo.Rev.Stat. 38-35-201 and 204 allow for any deed of trust,

assignment or other written instrument affecting real property to be invalidated. Independently

actionable civilly. Prevailing party can recover attorneys fees and cost; 2. The criminal forgery

statute should be actionable civilly pursuant to the Colorado Consumer Protection Act,

Colo.Rev.Stat. 6-1-105(1)(c) and 201. any person has been construed to allow for a private

right of action. See Hall v. Walter, 969 P.2d 224, 230-232 (Colo 1998). Common Law or Civil

Fraud Statute: 1. Common Law Fraud: To establish fraud, the plaintiff must show the defendant

made a false representation of a material fact, knowing that representation to be false; that the

person to whom the representation was made was ignorant of the falsity; that the representation

was made with the intention that it be acted upon; and, that the reliance resulted in damage to the

plaintiff. Coors v. Sec. Life of Denver Ins. Co., 112, P3d 59, 66 (Colo 2005)

14. Throughout the proceedings of 2011CV4858 CASSINO staunchly asserted that

no other party had any ownership interest in MR. CASSINOs property.

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15. CHASE knew or should have known prior to filing complaint to reform the deed

of trust and then foreclose with Case No. 2011CV4858 that they were not a real party in interest

because, as a snip of a Chain of Title Assessment Report provided by planned expert witness

Dave Krieger shows there is a broken chain of title caused by the false and fraudulent Corporate

Assignment Of Deed Of Trust dated 9/21/2011, a snip of the report is attached hereto as

Plaintiffs Exhibit L - Chain of Title Assessment Report Snip.

16. MR. CASSINO properly raised the issue of whether CHASE was the real party in

interest at the beginning of proceedings in previous case No. 2011CV4858.

17. Additional confirmation that CHASE was only operating in the capacity of a

Servicing Agent with respect to MR. CASSINOs loan is shown in CHASES mailed monthly

statement see Exhibit E - Chase Mortgage Loan Statement dated June 16, 2017.

18. CHASE had no valid ownership interest in MR. CASSINOs property therefore

they could not have suffered any injury in fact. The party bringing the action must be an actual

aggrieved party entitled to pursue a remedy. As a result, this Court lacked jurisdiction over the

parties in Case No. 2011CV4858 because there was never any injured party, a real party in

interest before the Court, and it certainly was not CHASE then or now.

19. In addition, the evidence shows that the Notice of Election and Demand For Sale

that CHASE filed with the Jefferson County Public Trustee is false and fraudulent, (said Notice

is attached hereto as Plaintiffs Exhibit H - Notice of Election and Demand For Sale.

20. CHASE certified in the Notice of Election and Demand For Sale to the Jefferson

County Public Trustee that these two statements were true and correct:

a. That they were the holder of the evidence of debt.

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b. That they were the current beneficiary of the Deed of Trust.

Both of these statements are absolutely false.

21. CHASE was not a Qualified Holder by any definition found in Colorado statutes,

and was not the current beneficiary of the Deed of Trust.

22. The original Deed of Trust presented by CHASE showed Community Mortgage

Group, Inc., as the beneficiary not CHASE - see Exhibit M - Cassino Deed of Trust 9-26-2005

with Community Mortgage Group, Inc. page 1 of 10.

23. Chase had 6 years to sue Cassino to collect. Chase forced Cassino to default by

not excepting regular monthly payments on 1/15/2011 period making last payment by Cassino

12/15/2010 6 days before Mitch J. Stein & Associates notified CHASE they were now

representing Cassino for either a real loan modification after 4 qualified attempts by Cassino

2009-2010 were denied only if CHASE was note holder in due course to do so or otherwise a

Quiet Title demanded and sought legally. That is why Chase on 3/17/2011 - 3 months after

Cassino last accepted (v. denied) 12/15/2010 payment - filed a fraudulent Notice of Election and

Demand For Sale. In total retaliation for retaining attorney Mitch J. Stein for either a honest loan

modification or a quiet title. Chase is time barred per as contract actions, including personal

contracts and actions under the UCC: 3 years (C.R.S. 13-80-101), except as otherwise provided

in 13-80-103.5; All claims under the Uniform Consumer Credit Code, except sections 5-5-

201(5); All actions to recover, detain or convert goods or chattels, except as otherwise provided

in section 13 -80-103.5. Liquidated debt and unliquidated determinable amount of money due;

Enforcement of instrument securing the payment of or evidencing any debt; Action to

recover the possession of secured personal property; Arrears of rent: 6 years, (C.R.S. 13-80-

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103.5) The 6-year statute of limitations started March 17, 2011 when CHASE filed their Notice

of Election and Demand For Sale and ended March 18, 2017. It was not tolled by the illegal

contract CHASE entered into with no capacity, interest or standing the Settlement

Agreement made March 15, 2013 was only good for one year besides the fact that CHASE

defaulted on it anyway when the 2 law firms representing CHASE - that made and signed the

settlement as attorneys for CHASE - withdrew from representing CHASE.

24. The meaning of HOLDER can be found in C.R.S. 38-38-100.3:

The following persons are presumed to be the holder of an evidence of debt:

(a) The person who is the obligee of and who is in possession of an original evidence

of debt;

(b) The person in possession of an original evidence of debt together with the

proper indorsement or assignment thereof to such person in accordance with section 38-38-

101(6);

(c) The person in possession of a negotiable instrument evidencing a debt, which has

been duly negotiated to such person or to bearer or indorsed in blank, or

(d) The person in possession of an evidence of debt with authority, which may be

granted by the original evidence of debt or deed of trust, to enforce the evidence of debt as agent,

nominee, or trustee or in a similar capacity for the obligee of the evidence of debt.

25. None of these definitions of a HOLDER applies to CHASE.

26. CHASE never represented themselves to be only functioning in the capacity of a

servicing agent that had been granted the authority to enforce the note on behalf of another. They

always insisted they were the only real party in interest.

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27. To date its not clear who, if anybody, owns MR. CASSINOs Note or who holds

good title.

VII. CLAIM FOR RELIEF

28. Plaintiff hereby incorporates by reference paragraphs 1 through 27, above, as

though fully set forth herein.

29. Because CHASE was not the owner of the Note in question, they were not

entitled to payment of the Note and did not have standing to initiate a foreclosure action against

MR. CASSINO. Therefore, the wrongful foreclosure attempt by CHASE in Case No.

2011CV4858 on November 16, 2011 in this court, is moot and void, as CHASE could not have

acquired good title to the subject property through a hoped for foreclosure sale.

30. Because CHASE could not have good title to the subject property in any shape or

form, CHASE could not and still not convey good title to anybody.

31. Mr. CASSINO remains the owner of the property as the wrongful foreclosure

attempt in Case No. 2011CV4858 that purported to divest him of title is moot and void.

32. Mr. CASSINO reserves the right to amend this complaint as needed and planned.

WHEREFORE, Plaintiff prays for the following relief:

a. That in equity this Court enter an order quieting title to the subject property in

Plaintiffs name, a result that would be just and fair to Plaintiff Cassino based on CHASEs own

very bad criminal acts.

b. For costs, attorneys fees, and such other and further relief as the Court deems

appropriate.

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GENERAL NOTICE- almost judicial: Plaintiff Cassino is also filing within 2-3 weeks or

sooner, a separate lawsuit - with a personal injury attorney of record leading a legal team - for $6

million in financial damages suffered from CHASE acts over the last 6 plus years to family

members. The 5 Plaintiffs are: himself, his 92-year-old mother, his 66-year-old brother (now

one month into rehab/nursing home care that Cynthia was made aware of in email

communications seeking release of CHASE alleged lien to close/sell neighbor .4 acres for

$11,600 on 7/3/2017 to settle lawsuit on their home encroachment documented at

www.CassinovJordans.weebly.com and then to sell/close remaining 4.7 acres for $145.000 by

7/15/2017 proceeds to help brother and mother with in home nursing care), his son and his

daughter for Personal Injury from an intentional Wrongful Foreclosure attempt with causes of

action: Mortgage Malpractice (like Medical Malpractice), Fraudulent foreclosing documents,

FDCPA violations, TILA, Consummation, Statute of Limitations and more. Bottom line,

CHASE could end or mitigate the 2nd law suit by simply providing releases on their fraudulent

lien so the 2 closings above can proceed without delay and without causing more financial

damages for the Cassinos to be compensated.

Dated this 28th day of June 2017.

By:

______________________________

Lance Cassino Pro Se


until attorney retained
POB 1050
Conifer, CO 80433
303-838-0221
lancecassino@msn.com

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Complaint for Quiet Title Under Rule 105 - Exhibits Summary

Exhibit A - JPMorgan Chase ADMITS not the successor in interest to WaMu loans.

Exhibit B - Settlement Agreement March 15, 2013.

Exhibit C - Personal Representative's Deed recorded 7/19/1999 conveying title to 40 acre

parcel with home to Lance R. Cassino.

Exhibit D - Personal Representative's Deed recorded 12/16/1999 conveying title to 5.1

vacant acre parcel to Lance R. Cassino.

Exhibit E - Chase Mortgage Loan Statement dated June 16, 2017 stating an inaccurate

amount and date while admitting it is a debt collector

Exhibit F - Rescission Letter dated January 30, 2015 recorded in the Jefferson County land

records.

Exhibit G - Letter to Mr. Jamie Dimon dated May 3, 2016 offering out of court settlement.

Exhibit H - Notice of Election and Demand For Sale.

Exhibit I - Corporate Assignment of Deed of Trust dated 9/21/2011 filed 9/28/2011.

Exhibit J - Forensic Examination Report dated June 15, 2017 on Corporate Assignment of

Deed of Trust dated 9/21/2011 - 19 pages.

Exhibit K - Forensic Examination Report dated March 30, 2017 on Affidavit of Lost Note

dated 4/24/2012 and Affidavit of Lost Instrument dated 12/13/2012 - 26 pages.

Exhibit L - Chain of Title Assessment Report Snip.

Exhibit M - Cassino Deed of Trust 9-26-2005 with Community Mortgage Group, Inc. page

1 of 10.

THE ABOVE EXHIBITS ARE A SEPARATE DOCUMENT CONTAINING 78 PAGES.

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