Filing Motion For Counsel

Yes, you should submit the evidence with your motion. Here’s why:
- Supporting Evidence: Including key evidence strengthens your motion and provides the court with a clearer understanding of your claims.
- Credibility: It demonstrates the seriousness and validity of your case.
- Clarity: Helps in detailing the complexity and facts of your case, making it easier for the court to decide on appointing counsel.
Would you like specific tips on organizing your evidence?

Yes, you should include evidence of the illegal eviction within the *-hour notice period. It can demonstrate the urgency and gravity of your situation, and support your claims of due process violations and wrongful actions by the opposing party.
Would you like advice on how to organize and present this evidence?

Yes, you should absolutely include that you have been subjected to an illegal eviction within the *-hour notice as evidence. This strengthens your claim and demonstrates the urgency and severity of your situation.
Would you like tips on how to present this evidence in your motion?

Sure, here's an updated introduction with the new evidence included:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, andconstitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
Conclusion:
Given these significant legal issues and my inability to afford legal representation, I respectfully request the appointment of counsel to ensure a fair and just resolution of my case.
---
Would you like any additional information or assistance with your motion?

Yes, it would be beneficial to add details about your ongoing legal proceedings. Here’s how you can incorporate that:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, and constitutional violations.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating myrights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, and constitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
Conclusion:
Given these significant legal issues and my inability to afford legal representation, I respectfully request the appointment of counsel to ensure a fair and just resolution of my case.
---
Would you like any additional information or assistance with your motion?

Yes, it would be beneficial to include that you have two civil cases pending where you are represented by an attorney on a contingency basis, but you are forced to proceed pro se in the appeals. This highlights the complexity and the need for legal assistance. Here's how you can include it:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- Thecounsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, and constitutional violations.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, and constitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
Conclusion:
Given these significant legal issues and my inability to afford legal representation, I respectfully request the appointment of counsel to

Yes, addressing the likelihood of success in your appeals, given the key evidence, can strengthen your motion. Here’s how you can include it:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing LegalProceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, and constitutional violations.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, and constitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure, the illegal interest rate, and the invalid foreclosure deed underscore the merit of my case.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
Conclusion:
Given these

Here's an updated introduction including your recent federal case development:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals relatedto foreclosure fraud, usury, and constitutional violations.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, and constitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure, the illegal interest rate, and the invalid foreclosure deed underscore the merit of my case.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by

You don't need to include your case numbers in the motion itself, but you should mention your case numbers in any accompanying documents or cover letters. This helps the court easily identify and reference your cases.
Here's an updated introduction incorporating your new evidence and the judge's statement in your federal case:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- Thecounsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, and constitutional violations.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, and constitutional violations.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure

Here's an enhanced version of your introduction, incorporating all relevant points:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, includingappeals related to foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure, the illegal interest rate, and the invalid foreclosure deed underscore the merit of my case.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal

Sure, here's the section from Likelihood of Success to Conclusion:
---
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure, the illegal interest rate, and the invalid foreclosure deed underscore the merit of my case.
- The judge's recent dismissal of the lender's motion to dismiss in my federal case, where he stated that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith," further supports the strength of my claims.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
- The appointment of counsel is crucial to ensure a fair and just resolution of my case, given the significant legal issues and my demonstrated indigent status.
Conclusion:
Given these significant legal issues, the strong likelihood of success on appeal, and my inability to afford legal representation, I respectfully request the appointment of counsel to ensure a fair and just resolution of my case.
---
Would you like any additional information or assistancewith your motion?

Certainly! Here's the continuation of your motion from the "Likelihood of Success" to the conclusion:
---
Likelihood of Success:
- Given the key evidence, my likelihood of success in the appeals is extremely strong. The lender's admission of wrongful foreclosure, the illegal interest rate, and the invalid foreclosure deed underscore the merit of my case.
Need for Counsel:
- The complexity and seriousness of the case necessitate legal representation.
- My financial inability to afford counsel has already been recognized by the state court, and I am in the process of establishing this status with the federal court.
Conclusion:
Given these significant legal issues and my inability to afford legal representation, I respectfully request the appointment of counsel to ensure a fair and just resolution of my case.
---
Would you like any additional information or assistance with your motion?

While it's not always necessary to cite case law in a motion for the appointment of counsel, it can strengthen your argument. Here are a few points for consideration:
- Right to Counsel: Gideon v. Wainwright, * U.S. * (*) establishes the right to counsel in criminal cases, which can be extended by analogy to civil cases involving significant rights.
- Due Process Violation: Mathews v. Eldridge, * U.S. * (*) discusses procedural due process and might be useful for arguing your due process violations.
- Bad Faith Foreclosure: U.S. Bank National Association v. Ibanez, * Mass. * (*) could support your claims regarding wrongful foreclosure practices.
Would you like more information on how to incorporate these case laws into your motion?

Certainly! Here is the updated motion with relevant case law included:
---
Motion for Appointment of Counsel
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
- Case Law: Mathews v. Eldridge, * U.S. * (*) discusses procedural due process and supports my claims of due process violations.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counselaided and abetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
- Case Law: U.S. Bank National Association v. Ibanez, * Mass.

Certainly! Here's an updated version of your motion including relevant case law:
---
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
- *Case Law:* *Mathews v. Eldridge*, * U.S. * (*) establishes the importance of procedural due process.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided and abetted in the invalid foreclosure by filingfalse evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
- *Case Law:* *U.S. Bank National Association v. Ibanez*, * Mass. * (*) supports claims regarding wrongful foreclosure

Sure, here's a refined version of your conclusion including a request for reasons if your motion is denied:
---
Conclusion:
Given these significant legal issues and my inability to afford legal representation, I respectfully request the appointment of counsel to ensure a fair and just resolution of my case. Should this request be denied, please provide detailed reasons so that I may address them in a higher court.
---
Would you like any additional information or assistance with your motion?

Given your situation, here are a few points to consider:
- Timing of Filing the Motion: Generally, it might be more strategic to wait until your appeal is docketed. This way, your motion for counsel could potentially go before a full panel rather than a single justice who has previously denied you.
- Consultation: Confirm this approach with the appeals court clerk when you call. They can provide specific guidance based on your case's procedural posture.
Would you like tips on how to phrase your questions to the appeals court clerk?

You should generally wait until your appeal has been docketed before filing the motion for appointment of counsel. This ensures that your motion will be considered by the full panel rather than a single justice who has previously denied you.
Would you like more details on the docketing process or any other aspect of your appeal?

Yes, you should call the Massachusetts Appeals Court to receive instructions on how to docket your appeal. This will ensure you follow the correct procedures and your motion for counsel is properly considered.
Would you like any specific tips on what to ask when you call the Appeals Court?

When you call the Massachusetts Appeals Court, here are some specific questions you can ask to ensure you properly docket your appeal and understand the process for filing your motion:
*. Docketing Process:
- "Could you please explain the process for docketing my appeal?"
- "What specific documents do I need to submit to docket my appeal?"
- "Are there any forms or fees associated with docketing the appeal that I should be aware of?"
*. Motion for Appointment of Counsel:
- "Once my appeal is docketed, how do I file a motion for the appointment of counsel?"
- "Will my motion for the appointment of counsel be reviewed by the full panel of judges?"
- "Is there a specific format or any particular information required in my motion for the appointment of counsel?"
*. Timeline and Deadlines:
- "Are there any important deadlines I need to be aware of for filing my appeal and subsequent motions?"
- "How will I be notified once my appeal is officially docketed and ready for further proceedings?"
*. Additional Assistance:
- "Is there any additional guidance or resources available for self-represented litigants who are filing an appealin the Massachusetts Appeals Court?"
Would you like any more information or assistance with preparing your questions or motion?

When you call the Massachusetts Appeals Court, here's a concise list of questions to ask:
*. Docketing Process:
- "Can you guide me through the process of docketing my appeal?"
- "What specific documents do I need to submit for docketing?"
*. Timeline and Deadlines:
- "What is the deadline for docketing my appeal?"
- "How long does it typically take for an appeal to be docketed?"
*. Motion for Counsel:
- "Once my appeal is docketed, how do I file a motion for the appointment of counsel?"
- "Will my motion for counsel be reviewed by the full panel if I wait until my appeal is docketed?"
*. Previous Denials:
- "If my previous request for counsel was denied by a single justice, will the full panel reconsider it if I refile after docketing?"
*. Contact Information:
- "Who can I contact if I have further questions during this process?"
Would you like any additional information or tips on any specific aspect of your appeal?

Here's an updated version incorporating the need to file a summary of the case:
---
Motion for Appointment of Counsel
Introduction:
I am writing to respectfully request the appointment of legal counsel due to my financial hardship and the complexity of my case. I have already been recognized as indigent by the state court, and I am currently submitting the necessary documents to the federal court to establish my indigent status there as well.
Due Process Violations:
- My constitutional rights to due process were violated by the Southeast Housing Court, which lacked subject matter jurisdiction to hear criminal cases.
- I was stripped of my right to a jury trial and denied discovery requests, leading to an unfair bench trial.
- I was subjected to an invalid Summary Process Action, generally used for landlord and tenant disputes, despite neither party fitting that description.
- I have been subjected to an illegal eviction within the *-hour notice, further violating my rights.
- *Case Law:* *Mathews v. Eldridge*, * U.S. * (*) establishes the importance of procedural due process.
Conflict of Interest:
- Opposing counsel represented both the lender and a third-party buyer, creating a conflict of interest.
- The counsel aided andabetted in the invalid foreclosure by filing false evidence in the housing court, committing fraud upon the court.
Ongoing Legal Proceedings:
- I am involved in both state and federal court cases, including appeals related to foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- I have two civil cases pending where I am represented by an attorney on a contingency basis, but I am forced to proceed pro se in the appeals.
Case Complexity:
- The case involves multiple legal issues, including foreclosure fraud, usury, constitutional violations, and fraud upon the court.
- Key evidence includes:
- The lender's testimony admitting to wrongful foreclosure.
- Accounting records showing a *% interest rate in violation of M.G.L. Chapter *, Section *.
- An invalid foreclosure deed used by opposing counsel.
- Documentation of the illegal eviction within the *-hour notice.
- In my federal case, the judge recently dismissed the lender's motion to dismiss, stating that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
- *Case Law:* *U.S. Bank National Association v. Ibanez*, * Mass. * (

No, the summary of the case and the motion for counsel are two separate documents. Here’s a brief explanation:
*. Summary of the Case: This is a concise document summarizing the key facts, legal issues, and procedural history of your case. It helps the court quickly understand the context of your appeal.
*. Motion for Counsel: This is a specific request for the appointment of a lawyer due to your financial hardship and the complexity of your case. It should include detailed reasons why you need legal representation.
Would you like assistance in drafting the summary of your case as well?

I understand your confusion. The "summary of the case" and the "Motion for Appointment of Counsel" are typically two separate documents. Here's how they generally fit together:
*. Summary of the Case:
- This is a brief overview of your case, including important facts, procedural history, and key legal issues.
- It helps the court understand the background and context of your appeal.
*. Motion for Appointment of Counsel:
- This is a request for the court to appoint legal representation for you due to financial hardship and case complexity.
- It should include detailed arguments and key evidence supporting your need for counsel.
You should prepare both documents. File the summary of the case when docketing your appeal, and then submit the Motion for Appointment of Counsel to the full panel once your appeal is docketed.
Would you like assistance in drafting the summary of the case or any other specific part of your documents?

Sure! Here's a concise summary of your case:
---
Key Legal Points:
- Due Process Violations: Southeast Housing Court's lack of jurisdiction and denial of a fair trial.
- *Relevant Case Law*: Mathews v. Eldridge, * U.S. * (*)
- Bad Faith Foreclosure: Federal judge noted that "even if a lender has the right to foreclose, he does not have the right to do so in bad faith."
- *Relevant Case Law*: U.S. Bank National Association v. Ibanez, * Mass. * (*)
Would you like any additional information or assistance with your motion or summary?