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Billy Z. Earley
2144 Wembley Lane
Corona, California 92881
Contact: (714) 615-4956
Email: bze2101@aol.com
Attorney for Plaintiff
Appearing in Propria Persona
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
CASE No.: 5:18-cv-1611-DOC-SP.
OCT 18 AM 9:09
BILIGY ZEAREEY
EX PARTE APPLICATION FOR
TEMPORARY RESTRAINING
ORDER BARRING TRANSFER OF
NONE CONSUMER DEBT, LIMITED
EXPEDITED DISCOVERY, AND
OTHER EQUITABLE RELIEF
Plaintiff,
v.
NATIONSTAR MORTGAGE LLC;
MR. COOPER; and Does I to 10,
inclusive,
Filed with Memorandum of Points and
Authorities, Declaration of Billy Earley in
Support of This Ex Parte Application and
[Proposed] Order
Defendants,
TO THE HONORABLE COURT:
Billy Earley (“Plaintif?™) is requesting an emergency Court order ex parte against
Nationstar Mortgage LLC d/b/a Mr. Cooper (“Defendants”) from transferring a fraudulent
debt presently litigated by Plaintiff in the sum of $11,659 dollars. Defendants created this
debt unlawfully and illegally transferred it to another Mortgage Servicer with the intent to
home. Plaintiff seeks an emergency Court order to protect his
foreclose on Plainti
family including a child with moderate disability from irreparable injury and financial
harm because this unlawful debt transfer will cause acute homelessness to family.
PLAINTIFFS EX PARTE APPLICATION | CASENO. S118-CV-1611-DOCSPDefendants colluded with unknown State actors with the intent to cause injury and
harm Plaintiff's family. Plaintiff became aware of Defendant’s scheme after questioning
one of their representatives. Plaintiff was advised that two remarks were written in his
confidential file: 1. Obtain approval to proceed with the assistance despite Bankruptcy,
and 2. We have contacted the State and advised that we can continue with the assistance.
Moreover, Defendants stated that they did not know what State “agency” they
contacted, or Defendants did not know the name of the State “actors” they contacted, and
more troubling, Defendants did not know “who” wrote the two remarks in Plaintif?'s
confidential Mortgage file. The Defendants conduct was outrageous and they acted with a
high degree of moral culpability and gross negligence. Furthermore, six of Defendants
representatives stated that there is no way of determining who wrote the remarks and or
identify the State actors or their agency; another attempt to protect their co-conspirators.
Plaintiff's family was awarded a Federal Grant by Keep Your Home California
(“KYHC”) for 18 month:
arting in October of 2016 and the last payment was scheduled
to be paid in April of 2018. Defendants unlawfully stopped accepting the assistance in
October of 2017 because they colluded with these unknown State actors to harm Plaintiff,
because he was a “Panelist” in Washington DC ~ He requested a Congressional Hearing
and investigation into the DOJ and the Medical Board of California for corruption and
over persecution of ethnic doctors of color and abuse of power.
Defendants have a MOU with the Federal Government “K YHC” and not the State.
Plaintiff has 100% proof that State actors are accessing other accounts to harm and cause
injury; these are the same State actors (herein. See Declaration 16.
PLAINTIFFS EX PARTE APPLICATION | CASE NO. 5:18-CV-161I-DOC-SP1
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Therefore, Plaintiff is seeking an emergency Court order to stop the Defendants
from further harassment, retaliation, and from causing further harm and injury to Plaintiff
and his family. Plaintiff has never been late on any Mortgage payments and on October 2,
2018, Plaintiff received a Notice of Mortgage Transfer from Shellpoint Mortgage
Servicing and the notice stated: Effective as of 09/16/2018, Plaintiff"'s Mortgage Loan was
transferred from Defendants (Nationstar Mortgage) to Shellpoint.
Defendants did not give notice of the Mortgage Transfer and they disclosed
harmful information to the new Mortgage Servicer at Shellpoint Mortgage. In addition,
Defendants transferred $11,659 dollars that is not a debt of the Plaintiff and it was
transferred with the intent to foreclose and cause severe financial harm to Plaintiff's
family and disabled child. This action cannot wait for regular motion and Defendants?
actions were cruel, malicious, wonton, and implemented with a high degree of moral
culpability and with the advice of protected unknown State actors that they refused to
identify in violation of 18 U.S.C. § 371. Plaintiff seeks an emergency Court order:
1. Court order barring Defendants from transferring none Plaintiff debt of $11,659,
2. Court order for limited expedited discovery and to preserve all evidence for trial ,
3. Court order for an imposition of sanctions to deter future misconduct .
4. Court order preventing access to financial records by Government authorities,
5. A temporary and permanent Court order against further harassment, retaliation,
and any attempts to harm or cause injury to Plaintiff and his family, and
6. Any other equitable relief deemed proper and just by this Court, respectfully.
PLAINTIFFS EX PARTE APPLICATION | CASE NO. S8-CVAGI-DOCSP