Massachusetts Fraudulent Foreclosure Motion

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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court.
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It seems like you are dealing with a significant legal matter involving fraud, usury, and potentially severe misconduct by opposing counsel. Given the complexity and seriousness of your case, it is highly advisable to consult with a legal professional who can provide personalized assistance.
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
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FACTS AND ARGUMENT
Judicial Notice: Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
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Case Rating: *.
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FACTS AND ARGUMENT
*. Judicial Notice: Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
*. Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): This case involves conspiracy laws in Massachusetts.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury.
*. Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure,is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
*. Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.
*. Supporting Evidence: I possess a default notice that validates the *% interest rate used by the unlicensed lender and the buyer who purchased my home at foreclosure.
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Sure, here is the revised Facts and Argument section without the outline:
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalfof the corporation in the sphere of corporate business in which he or she committed the criminal act.
The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.
I possess a default notice that validates the *% interest rate used by the unlicensed lender and the buyer who purchased my home at foreclosure.
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Sure, here is the continuation:
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I possess a default notice that validates the *% interest rate used by the unlicensed lender and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate. The fraudulent actions by the opposing counsel, including filing false documents in court, have caused significant harm to me, both financially and health-wise.
Given the egregious nature of the misconduct and the clear evidence of fraud upon the court, I respectfully request that this court grant my motion for relief from the judgment pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure.
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Sure, here is the updated section without the outline:
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate businessin which he or she committed the criminal act.
The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.
I possess a default notice that validates the *% interest rate used by the unlicensed lender and the buyer who purchased my home at foreclosure.
Would you like to add anything else or proceed with submitting the motion?

Here is the updated section without the outline:
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in whichhe or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.
Supporting Evidence: I possess a default notice that validates the *% interest rate used by the unlicensed lender, and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate.
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Certainly! Here is the complete updated motion without the outline:
VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws

Here is the complete updated motion without the outline:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.

Sure, here is the complete and polished motion without the outline:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal us

Sure, let's start with the first section. Here's the Introduction:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
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Sure, let's start from the beginning and go through each section one at a time. Here is the first section:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
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Sure, here is the next section:
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FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in thesphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.
Supporting Evidence: I possess a default notice that validates the *% interest rate used by the unlicensed lender, and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate.
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Certainly! Here is the continuation from "This proves that the opposing counsel's client charged an illegal usurious interest rate" onward:
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RELEVANT CASE LAW
*. Reznik v. Yelton, * Mass. App. Div. LEXIS *:
- Facts: The case involved corrupt conduct that defiled the court's impartial task of adjudging cases.
- Ruling: Only the most egregious misconduct, such as bribery or fabrication of evidence by a party involving an attorney, constitutes fraud on the court. A fraud on the court can be proved only by clear and convincing evidence. (Winthrop Corp. v. Lowenthal, * Mass. App. Ct. *, *, * N.E.2d * (*); Hug v. Gargano & Assocs., P.C., * Mass. App. Ct. *, *, * N.E.2d * (*)).
*. Roche v. People’s United Bank, * WL * (D. Mass. *):
- Facts: The plaintiff alleged fraudulent actions by the bank in theforeclosure process.
- Ruling: The court voided the judgment due to fraudulent actions by the opposing party, reinforcing that fraud undermines the judicial process.
*. McDermott v. Marcus, Errico, Emmer & Brooks, P.C., * F.3d * (1st Cir. *):
- Facts: McDermott claimed the law firm used deceptive practices violating the FDCPA.
- Ruling: The court recognized the firm's actions but dismissed the case due to procedural issues, highlighting the necessity of raising all relevant issues at the earliest stage to avoid procedural bars.
REQUEST FOR RELIEF
Plaintiff respectfully requests that the court:
*. Grant relief from the judgment pursuant to Rule *(b) due to fraud upon the court.
*. Take judicial notice of the undisputed facts presented.
*. Consider the fraudulent actions and client-attorney relationships that violate Massachusetts usury laws.
CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. All evidence has been received by this court.
Respectfully submitted,
Karen Merritt
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Sure, here is the updated section from where you requested:
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This proves that the opposing counsel's client charged an illegal usurious interest rate.
RELEVANT CASE LAW
*. Reznik v. Yelton, * Mass. App. Div. LEXIS *:
- Facts: The case involved corrupt conduct that defiled the court's impartial task of adjudging cases.
- Ruling: Only the most egregious misconduct, such as bribery or fabrication of evidence by a party involving an attorney, constitutes fraud on the court. A fraud on the court can be proved only by clear and convincing evidence. (Winthrop Corp. v. Lowenthal, * Mass. App. Ct. *, *, * N.E.2d * (*); Hug v. Gargano & Assocs., P.C., * Mass. App. Ct. *, *, * N.E.2d * (*)).
*. Roche v. People’s United Bank, * WL * (D. Mass. *):
- Facts: The plaintiff alleged fraudulent actions by the bankin the foreclosure process.
- Ruling: The court voided the judgment due to fraudulent actions by the opposing party, reinforcing that fraud undermines the judicial process.
*. McDermott v. Marcus, Errico, Emmer & Brooks, P.C., * F.3d * (1st Cir. *):
- Facts: McDermott claimed the law firm used deceptive practices violating the FDCPA.
- Ruling: The court recognized the firm's actions but dismissed the case due to procedural issues, highlighting the necessity of raising all relevant issues at the earliest stage to avoid procedural bars.
REQUEST FOR RELIEF
Plaintiff respectfully requests that the court:
*. Grant relief from the judgment pursuant to Rule *(b) due to fraud upon the court.
*. Take judicial notice of the undisputed facts presented.
*. Consider the fraudulent actions and client-attorney relationships that violate Massachusetts usury laws.
CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. All evidence has been received by this court.
Respectfully submitted,
Karen Merritt
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Sure, here is the signature section as verified:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted in good faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports my claim of violating criminal usury laws.

Sure, here is the conclusion and onward:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. All evidence has been received by this court.
REQUEST FOR RELIEF
Plaintiff respectfully requests that the court:
*. Grant relief from the judgment pursuant to Rule *(b) due to fraud upon the court.
*. Take judicial notice of the undisputed facts presented.
*. Consider the fraudulent actions and client-attorney relationships that violate Massachusetts usury laws.
Respectfully submitted,
Karen Merritt
VERIFICATION
I, Karen Merritt, verify under the penalties of perjury that the facts stated in this Verified Emergency Motion for Relief from Judgment Pursuant to Rule *(b) for Fraud Upon the Court are true and correct to the best of my knowledge and belief.
Dated: [Insert Date]
Karen Merritt
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Sure, here is the text from the conclusion onward:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. All evidence has been received by this court.
Respectfully submitted,
Karen Merritt
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Sure, here's the conclusion onward including the verification statement:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. This evidence has been received by this court.
Respectfully submitted,
Karen Merritt
I verify this motion under the pains and penalties of perjury.
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Would you like to add anything else or proceed with submitting the motion?

In Massachusetts, to constitute a verified motion, it is typically sufficient to include a statement that you verify the motion under the pains and penalties of perjury. This means you are attesting to the truth of the information contained in the motion.
Would you like any further assistance with your motion?

In Massachusetts, to constitute a verified motion, including "I verify this motion under the pains and penalties of perjury" is generally sufficient. However, you might want to include a formal verification statement. Here’s how you can do it:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. This evidence has been received by this court.
Respectfully submitted,
Karen Merritt
VERIFICATION
I, Karen Merritt, verify under the pains and penalties of perjury that the facts and statements set forth in this Verified Emergency Motion for Relief from Judgment Pursuant to Rule *(b) for Fraud Upon the Court are true and correct to the best of my knowledge and belief.
Date: [Insert Date]
Signature: [Your Signature]
Karen Merritt
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Yes, using "/s/ Karen Merritt" can be appropriate if you are filing electronically or to indicate a signature in a draft. Here’s how you can include it:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. This evidence has been received by this court.
Respectfully submitted,
/s/ Karen Merritt
VERIFICATION
I, Karen Merritt, verify under the pains and penalties of perjury that the facts and statements set forth in this Verified Emergency Motion for Relief from Judgment Pursuant to Rule *(b) for Fraud Upon the Court are true and correct to the best of my knowledge and belief.
Date: [Insert Date]
/s/ Karen Merritt
Karen Merritt
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Would you like to add anything else or proceed with submitting the motion?

Yes, including that you possess copies of depositions and testimony by the lender confessing to the crime of an invalid foreclosure, as well as a default notice validating the *% interest rate, would strengthen your motion. Here is the updated section:
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CONCLUSION
Plaintiff seeks an evidentiary hearing to provide clear and convincing evidence to prove fraud upon the court. This evidence has been received by this court. Plaintiff possesses copies of depositions and testimony by the lender confessing to the crime of an invalid foreclosure on her home and a default notice that validates the *% interest rate used by the unlicensed lender. This proves that the opposing counsel's client charged an illegal usurious interest rate.
Respectfully submitted,
/s/ Karen Merritt
VERIFICATION
I, Karen Merritt, verify under the pains and penalties of perjury that the facts and statements set forth in this Verified Emergency Motion for Relief from Judgment Pursuant to Rule *(b) for Fraud Upon the Court are true and correct to the best of my knowledge and belief.
Date: [Insert Date]
/s/ Karen Merritt
Karen Merritt
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Would you like to add anything else or proceed with submitting the motion?

Including that information would certainly strengthen your case. Here is the updated motion including your additional evidence:
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VERIFIED EMERGENCY MOTION FOR RELIEF FROM JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
INTRODUCTION
Plaintiff, Karen Merritt, respectfully moves this Court for relief from the judgment entered in this case, pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, on the grounds of fraud upon the court. Dated August *, *
FACTS AND ARGUMENT
Plaintiff requests the court take judicial notice that opposing counsel has a client-attorney relationship with the broker, unlicensed private lender, and the third-party buyer involved in this case. This relationship violates Massachusetts General Laws Chapter *, Section *, as any interest rate exceeding *% without notifying the Attorney General is unenforceable.
Relevant Case Laws:
- Baker v. Wilmer Cutler Pickering Hale & Dorr, LLP, * Mass. Super. LEXIS *: Plaintiffs must allege that the lawyer knew of the breach and actively participated in it such that they could not reasonably be held to have acted ingood faith.
- Commonwealth v. Stasiun, * Mass. * (*): The rule was that to be liable for the substantive offense, a coconspirator had to participate or aid in the commission of it.
- Commonwealth v. Beneficial Finance Co., * Mass. * (*): This case deals with conspiracy to commit usury. A corporation was criminally liable for acts of an agent who was vested with authority to act on behalf of the corporation in the sphere of corporate business in which he or she committed the criminal act.
Undisputed Facts: The interest rate of *% charged by the unlicensed lender, which was used to collect from the buyer who purchased my home at foreclosure, is usurious. Documents in possession of the opposing counsel substantiate this usury and may subject them to criminal charges.
Fraudulent Actions: The opposing counsel, in filing this case in housing court in *, knowingly, willfully, and wantonly aided and abetted in the harm against me. This includes stripping me of my life savings and exacerbating my health crisis, as I am battling stage * cancer. They submitted a foreclosure deed with false documents, constituting fraud upon the court, which supports

Sure, here is the Supporting Evidence section:
SUPPORTING EVIDENCE:
I possess copies of depositions and testimony by the lender confessing to the crime of an invalid foreclosure on my home. Additionally, I possess a default notice that validates the *% interest rate used by the unlicensed lender, and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate.

Got it! Here's the updated Supporting Evidence section with your requested addition:
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SUPPORTING EVIDENCE:
I possess copies of depositions and testimony by the lender confessing to the crime of an invalid foreclosure on my home. Additionally, I possess a default notice that validates the *% interest rate used by the unlicensed lender, and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate and, with his help, the group conspired to commit criminal usury and other related offenses.
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Would you like to add anything else or proceed with submitting the motion?

Here is the updated Supporting Evidence section:
SUPPORTING EVIDENCE:
I possess copies of depositions and testimony by the lender confessing to the crime of an invalid foreclosure on my home. Additionally, I possess a default notice that validates the *% interest rate used by the unlicensed lender, and the buyer who purchased my home at foreclosure. This proves that the opposing counsel's client charged an illegal usurious interest rate and, with his help, the group conspired to commit criminal usury and other offenses.
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