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MJS & Associates

Law Offices of M. J. Stein

2950 Buskirk Avenue, Suite 300 Walnut Creek, California 94597.

Phone: 310 4218152 Fax: 310-988.2563


Liti gation D ah Management

Mitchell J. Stein
http ://www.dobielaw.or

Attorney-Client Privileged

Dear Client,

As we move into litigation with your file, we are providing you with an initial road map
of the course that we will take.

First, we will review any specifics as it relates to you and your lender, and qualify the
litigation as it pertains to your lender, and your transaction history with that lender. This
was explored within the QC intake call that you all ready have received.

Several other issues that pertain to your lender will also be investigated to determine if
they support the causes of action we intend to litigate. These "Causes of Action" may
include, but not be limited to the following charges agenst your lender.:

There are eight (8) causes of action; all but one of the causes (#6) are applicable to
all plaintiffs (plaintiffs means those who are suing-your lender is the is the
defendant in this suit). Cause of action (#6) is for those homeowners who have been
foreclosed upon.

A jury trial is requested.

Causes of Action:

1. FRAUDULENT CONCEALMENT [VIOLATTON OF CAL. CIV. CODE $$


1572,1709 AND 17101;
"Defendants had exclusive knowledge not accessible to Plaintiffs of material facts
pertaining to its mortgage lending activities that it did not disclose to Plaintiffs"

2. TNTENTTONAL MISREPRESENTATION [VIOLATION OF CAL. CrV. CODE


$$ 1572, 1709 AND t7t0l;

3. NEGLTGENT MTSREPRESENTATION [VTOLATION OF CAL. CIV. CODE $$


t572,1709 AND 17101;

4. TNVASION OF CONSTITUTIONAL RIGHT TO PRMCY IUOLATION OF


cAL. CONST., ART. I, $ 1l;

VIOLATION OF CALIFORNIA FINANCIAL INFORMATION PRIVACY


5.
ACT [CAL. FrN. CODE $S 40s0 TO 40601;

6. VIOLATTON OF CAL. CryIL CODE $ 2923.5;

Listed only on behalf for foreclosed clientso who are listed.

7. VIOLATION OF CAL. CML CODE $ 1798.82;

re: "Plaintiffs damages as a result of the foregoing also include loss of equity in their
houses, costs and expenses related to protecting themselves, reduced credit scores,
unavailability of credit, increased costs of credit, reduced availability of goods and
services tied to credit ratings, increased costs of those services, as well as fees and
costs, including, without limitation, attorneys' fees and costs"

8. UNFATR COMPETTTTON [VTOLATTONS OF CAL. BUS. & PROF. CODE $


17200 Er sEQ.l
Once our intake attorney has completed the intake interview with you, we will be in
contact with your Lender to make an initial demand with the intent of avoiding
aggressive and protracted Litigation. This demand will be directed to your Lender's
opposing counsel, within what is called a"998" form...
(htto://t$totv.lucba.ore/showpaee.cfm?pseeid:7491). We may receive a response, and
depending on said response, we will confer with you regarding resolution. We will then
respond to the opposing counsel. You will receive a copy of all settlement demands as
presented to your lender's attorneys. We also will be sending you a copy of the Law Suit,
and a copy of the complaint that indicates your status as a plaintive.
Also enclosed is a "Conversation Log" with which we would like you to update and
describe the nature of each phone conversation that you receive from your Lender or any
entity that might be calling regarding your Loan. Once we have filed a suit on your
behalf, we advise that you have no fuither conversations with your Lender at all, but
annotate each call with the date of the call and what they said in the call. These notes are
important to litigation.
There are rules as to conversation between the Plaintiff (you) and the Defendant (your
Lender) and we expect that your Lender may well step over the line. Should that occur,
that event may serve to enhance your litigation posture with your Lender.

We will be giving you updated litigation reports periodically.Please be aware this is a


Law Suit alleging serious violation of your rights and financial well being. As such, we
are not negotiating with your Lender outside of the structure ofjudicial oversight. There
will not be "updates" given on a weekly or bi-weekly basis. As the case matures andlor if
an offer is made on your behalf, you will be informed.

It is critical that you communicate with us regarding any paperwork that you receive from
your Lender. Copies should be Fax's to our attention, at : 310-988.2563.If you do not
have access to a FAX machine, mail those items to:
Attorney Processing Center atl80l2 Sky Park Circleo Suite l50,Irvine CA92614.

Should vou need clarification, vou muv call us at . Phone: 310 421 8152

Once again, you confidence in our firm is appreciated. You can be assured, we will be
swift and heavy handed in our litigation against your Lender as we turn the tide from
"Asking and Negotiating" with those that have proven to be incompetent or deceitful.
Your financial well being is our primary concern.

Litigation, asyou know, in anything but static. Tactics change; causes of action change,
hearings (battles) determine the next move. There is ongoing need to inform you as to
what is going on, as we fight this battle for you, and hopefully win the war. From
everything you have heard and read you know this is I-INPRECEDENTED in financial
history. http ://twcpn.com/movie.htm

Thank you,

Litigation Data Management

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