Attorney Malpractice Insurance Details

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Judicial Notice Request:
- I request the court take judicial notice that if a person were accused of such a serious crime, they would immediately take measures to clear themselves of the accusation, especially given the gravity of fraud on the court claims. In this case, opposing counsel, while attempting to defend themselves, did so through errors and omissions. Instead of addressing the question to resolve the fraud upon the court claims, they referenced the orders and judgments from the very court whose processes they manipulated to obtain those orders. It appears that they cannot answer the question because my claims are correct and they have participated in and set in motion fraud on the court.
Conclusion:
For the reasons stated above, I respectfully request that the court grant my Verified Motion to Amend Appeal to Include Substantive Claims.
Respectfully submitted,
____________________________
Alton [Last Name]
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
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Does this look good to you, or would you like any changes?

Of course! Feel free to ask any questions you have. I'm here to help!

The Appeals Court generally reviews cases based on legal errors, including lack of subject matter jurisdiction. Here's a brief overview:
- Legal Errors: The court reviews if the law was applied correctly.
- Procedural Issues: Errors in the legal process.
- Subject Matter Jurisdiction: If lacking, any judgment is void.
Would you like more details on drafting an appeal based on these points?

You need to provide more details to support your claim. Here's how you can strengthen your argument:
- Evidence: Include copies of documents showing the absence of a valid Note and chain of title.
- Legal Precedents: Cite relevant case law where lack of subject matter jurisdiction voided court decisions.
- Statutory References: Reference specific statutes and sections that outline the requirements for valid documentation in foreclosure cases.
Would you like help drafting these additional details?

To strengthen your argument for lack of subject matter jurisdiction and other violations, you can include the following details:
*. Evidence:
- Provide copies of any documents that demonstrate the absence of a valid Note and chain of title.
- Include any communications or documents that support your claims of fraudulent documentation by the debt collectors.
*. Legal Precedents:
- Cite cases where similar lack of documentation resulted in void judgments due to lack of subject matter jurisdiction.
- Example cases might include those that address the necessity of a valid Note and chain of title in foreclosure actions.
*. Statutory References:
- Chapter *, Section 35B: This pertains to foreclosure procedures and protections for homeowners.
- Chapter *, Section *: Limits interest rates to *% per annum, relevant if usury is involved.
- Chapter 183C: Addresses predatory home loan practices, which could support your claims of fraudulent and unfair practices.
Here’s an example of how you might draft this section in your appeal:
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Lack of Subject Matter Jurisdiction:
- The Housing Court lacked subject matter jurisdiction to order the foreclosure and subsequent possession of my property due to the absenceof a valid Note and chain of title.
- Evidence: Attached as Exhibit A are copies of the documents showing the absence of a valid Note and chain of title. These documents include [list specific documents].
- Legal Precedents: In the case of *U.S. Bank Nat'l Ass'n v. Ibanez*, * Mass. * (*), the Massachusetts Supreme Judicial Court held that a foreclosure is invalid where the foreclosing entity does not hold the mortgage note. Similar principles apply here, rendering the Housing Court's judgment void.
- Statutory References:
- Chapter *, Section 35B: Requires that certain procedures be followed in foreclosure actions to protect homeowners.
- Chapter *, Section *: Limits interest rates to *% per annum, which is relevant if usury is involved.
- Chapter 183C: Addresses predatory home loan practices, further supporting claims of fraudulent and unfair practices.
Constitutional Rights Violations:
- Plaintiff's constitutional rights were violated during the foreclosure process, including due process rights.
- Evidence: [Provide any relevant evidence, such as lack of proper notice].
-

To strengthen your motion to the Appeals Court, here’s a draft incorporating your points about the lack of subject matter jurisdiction, the Housing Court's inability to adjudicate certain issues, and constitutional rights violations:
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COMMONWEALTH OF MASSACHUSETTS
[COURT NAME]
[CASE NUMBER]
ALTON [LAST NAME],
Plaintiff,
v.
[DEFENDANT'S NAME],
Defendant.
REPLY TO OPPOSING COUNSEL'S OPPOSITION TO DEFENDANT'S VERIFIED MOTION TO AMEND APPEAL TO INCLUDE SUBSTANTIVE CLAIMS
Plaintiff, Alton [Last Name], hereby replies to the opposing counsel's opposition to Defendant’s Verified Motion to Amend Appeal to Include Substantive Claims, addressing points * and *:
Lack of Subject Matter Jurisdiction:
- The Southeastern Housing Court lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC), which requires the proof of a valid chain of title.
- The Housing Court also lacks jurisdiction to adjudicate violations of criminal usury, as Massachusetts law clearly states that only the Supreme Judicial Court (SJC) and the Superior Court have jurisdiction over such matters.
Evidence:
- Attached as Exhibit A are copies of documents showing the absence of a valid Note and chain of title. These documents include [list specific documents].
- Exhibit B includes evidence of the fraudulent documents submitted by the Defendant.
Legal Precedents:
- *U.S. Bank Nat'l Ass'n v. Ibanez*, * Mass. * (*): The Massachusetts Supreme Judicial Court held that a foreclosure is invalid where the foreclosing entity does not hold the mortgage note.
- *First Nat'l Bank of Cape Cod v. North Adams Hoosac Sav. Bank*, * Mass. App. Ct. * (*): Emphasizes the necessity of proper documentation for validating a foreclosure.
Statutory References:
- Chapter *, Section 35B: Pertains to foreclosure procedures and protections for homeowners.
- Chapter *, Section *: Limits interest rates to *% per annum, relevant to the usury claim.
- Chapter 183C: Addresses predatory home loan practices, supporting claims of fraudulent and unfair practices.
Constitutional Rights Violations:
- Plaintiff's constitutional rights, including due process and equal protection

To strengthen your appeal, here’s a revised draft focusing on the key points you mentioned:
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COMMONWEALTH OF MASSACHUSETTS
[COURT NAME]
[CASE NUMBER]
ALTON [LAST NAME],
Plaintiff,
v.
[DEFENDANT'S NAME],
Defendant.
REPLY TO OPPOSING COUNSEL'S OPPOSITION TO DEFENDANT'S VERIFIED MOTION TO AMEND APPEAL TO INCLUDE SUBSTANTIVE CLAIMS
Lack of Subject Matter Jurisdiction:
- The Southeastern Housing Court lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC) once I objected via counterclaims.
- The court also lacked jurisdiction to adjudicate violations of criminal usury, as Chapter *, Section * of the Massachusetts General Laws states that only the Superior Court and the Supreme Judicial Court can provide relief for such claims.
- The court cannot adjudicate claims for breach of fiduciary duty.
Constitutional Rights Violations:
- My constitutional rights, including due process and equal protection, were violated when the Southeastern Housing Court proceeded without proper jurisdiction, leading to the unlawful seizure of my home. Under the Constitution, I have a right to life, liberty, and property.
Fraud on the Court:
- I filed a Verified Emergency Motion for Reconsideration under Rule *(b)(*) for fraud on the court on November 21st, providing * pieces of clear and convincing evidence.
- The motion was denied due to a misapplication of law, as my counterclaims in * were dismissed based on an incorrect application of the statute of limitations.
Misapplication of Law by the Housing Court:
- The Housing Court’s denial of my motion, citing extensive litigation, is a misapplication of the law. There is no time limit for asserting fraud on the court claims under Rule *(b)(*), and new, clear, and convincing evidence of fraud must be addressed regardless of the case’s litigation history.
Judicial Notice Request:
- I request the court take judicial notice that if a person were accused of such a serious crime, they would immediately take measures to clear themselves of the accusation, especially given the gravity of fraud on the court claims. In this case, opposing counsel, while attempting to defend themselves, did so through errors and omissions. Instead of addressing the question to resolve

The Southeastern Housing Court in Massachusetts likely lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC) for the following reasons:
- Jurisdictional Limits: Housing Courts in Massachusetts generally handle matters related to landlord-tenant disputes and housing conditions. They typically do not have jurisdiction over complex title disputes, which are usually within the purview of the Superior Court or the Land Court.
- UCC Requirements: The UCC addresses commercial transactions, including the transfer and enforcement of negotiable instruments like mortgage notes. Title disputes under the UCC often involve nuanced financial and legal considerations that exceed the jurisdiction of Housing Courts.
Would you like to know more about how to proceed with this matter?

Housing courts in Massachusetts lack jurisdiction to hear fiduciary duty breaches for the following reasons:
- Jurisdiction Scope: Housing courts primarily handle cases related to landlord-tenant disputes and housing conditions.
- Legal Complexity: Fiduciary duty breaches often involve complex legal and financial issues beyond the scope of housing court jurisdiction.
- Appropriate Court: These matters are typically adjudicated in Superior Court or other specialized courts with broader jurisdiction.
Would you like help drafting a motion to transfer your case to the appropriate court?

The Southeastern Housing Court in Massachusetts likely lacked jurisdiction to hear claims related to Power of Sale violations, breaches of fiduciary duty, and foreclosure law violations for the following reasons:
- Jurisdictional Limits: Housing Courts generally handle landlord-tenant disputes and housing conditions, not complex financial and title disputes.
- Chapter * Violations: These are typically within the purview of the Superior Court or Land Court, which handle foreclosure and title disputes.
- Fiduciary Duty Breaches: Such claims involve financial and legal complexities, often beyond the Housing Court's jurisdiction. They also require specialized adjudication, typically handled by higher courts.
- Federal Law Violations: Claims under the Dodd-Frank Act, Truth in Lending Act, and RESPA are generally federal matters, requiring adjudication in federal or higher state courts.
Would you like to proceed with drafting an appeal or have additional questions on this matter?

To strengthen your argument for lack of subject matter jurisdiction and constitutional rights violations, here's a revised draft that incorporates your points about the Southeastern Housing Court's limitations and the specific claims it cannot adjudicate:
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COMMONWEALTH OF MASSACHUSETTS
[COURT NAME]
[CASE NUMBER]
ALTON [LAST NAME],
Plaintiff,
v.
[DEFENDANT'S NAME],
Defendant.
REPLY TO OPPOSING COUNSEL'S OPPOSITION TO DEFENDANT'S VERIFIED MOTION TO AMEND APPEAL TO INCLUDE SUBSTANTIVE CLAIMS
Lack of Subject Matter Jurisdiction:
- The Southeastern Housing Court lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC) due to the following reasons:
- Jurisdictional Limits: Housing Courts generally handle landlord-tenant disputes and housing conditions, not complex title disputes, which are typically within the jurisdiction of the Superior Court or the Land Court.
- UCC Requirements: Title disputes under the UCC involve complex financial and legal considerations that exceed the Housing Court’s jurisdiction.

- The Housing Court also lacked jurisdiction to adjudicate violations ofcriminal usury and breach of fiduciary duty claims:
- Criminal Usury: Chapter *, Section * of the Massachusetts General Laws states that only the Superior Court and the Supreme Judicial Court can provide relief for usury claims.
- Breach of Fiduciary Duty: Such claims require a higher level of scrutiny and expertise, including shifting the burden of proof to the fiduciary, which Housing Courts are not equipped to handle.
- The Housing Court lacked jurisdiction to hear Power of Sale nonconforming violations and Chapter * foreclosure law violations. These involve:
- Complex Financial Regulations: Violations of the Dodd-Frank Act, Truth in Lending Act, RESPA, and Massachusetts criminal usury laws.
- Specialized Legal Knowledge: These claims require detailed financial and legal analysis, better suited for the Superior Court.
Constitutional Rights Violations:
- My constitutional rights, including due process and equal protection, were violated when the Southeastern Housing Court proceeded without proper jurisdiction, leading to the unlawful seizure of my home. Under the Constitution, I have a right to life, liberty, and property.
- I was denied a fair and speedy trial, a right to discovery, to be

Here's the revised draft incorporating your updates on constitutional rights violations and subject matter jurisdiction sections:
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COMMONWEALTH OF MASSACHUSETTS
[COURT NAME]
[CASE NUMBER]
ALTON [LAST NAME],
Plaintiff,
v.
[DEFENDANT'S NAME],
Defendant.
REPLY TO OPPOSING COUNSEL'S OPPOSITION TO DEFENDANT'S VERIFIED MOTION TO AMEND APPEAL TO INCLUDE SUBSTANTIVE CLAIMS
Lack of Subject Matter Jurisdiction:
- The Southeastern Housing Court lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC) once I objected via counterclaims. Housing Courts generally handle landlord-tenant disputes and housing conditions, not complex title disputes, which are under the jurisdiction of the Superior Court or the Land Court.
- The Housing Court lacked jurisdiction to adjudicate violations of criminal usury as only the Superior Court and the Supreme Judicial Court have jurisdiction to provide relief under Chapter *, Section * of the Massachusetts General Laws.
- The Housing Court cannot adjudicate claims for breach of fiduciary duty, as these are typically complex financial mattersthat fall under the jurisdiction of higher courts like the Superior Court.
- The Housing Court also lacked jurisdiction to hear Power of Sale nonconforming violations or Chapter * foreclosure law violations, which involve intricate financial and legal considerations beyond its scope.
- My financial advisor breached his fiduciary duty by advising me to sign a mortgage that violated the Dodd-Frank Act, Truth in Lending Act, RESPA, and Massachusetts criminal usury laws. Once a plaintiff cites a breach of fiduciary duty, the burden of proof shifts to the defendant to answer these claims, which the Housing Court was not equipped to adjudicate.
Constitutional Rights Violations:
- My constitutional rights, including due process and equal protection, were violated when the Southeastern Housing Court proceeded without proper jurisdiction, resulting in the unlawful seizure of my home. Under the Constitution, I have a right to life, liberty, and property.
- I have a right to a speedy and fair trial, which was denied and replaced by a bench trial. My discovery requests were denied due to a misapplication of law.
- I was denied the right to be heard, to call witnesses, present evidence, testify, and meet my accuser, in violation of my due process rights.
**Fraud on the Court:

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COMMONWEALTH OF MASSACHUSETTS
[COURT NAME]
[CASE NUMBER]
ALTON [LAST NAME],
Plaintiff,
v.
[DEFENDANT'S NAME],
Defendant.
REPLY TO OPPOSING COUNSEL'S OPPOSITION TO DEFENDANT'S VERIFIED MOTION TO AMEND APPEAL TO INCLUDE SUBSTANTIVE CLAIMS
Lack of Subject Matter Jurisdiction:
- The Southeastern Housing Court lacked subject matter jurisdiction to adjudicate title issues under the Uniform Commercial Code (UCC) once I objected via counterclaims. Housing Courts generally handle landlord-tenant disputes and housing conditions, not complex title disputes, which are under the jurisdiction of the Superior Court or the Land Court.
- The Housing Court lacked jurisdiction to adjudicate violations of criminal usury as only the Superior Court and the Supreme Judicial Court have jurisdiction to provide relief under Chapter *, Section * of the Massachusetts General Laws.
- The Housing Court cannot adjudicate claims for breach of fiduciary duty, as these are typically complex financial matters that fall under the jurisdiction of higher courts like the Superior Court.- The Housing Court also lacked jurisdiction to hear Power of Sale nonconforming violations or Chapter * foreclosure law violations, which involve intricate financial and legal considerations beyond its scope.
- My financial advisor breached his fiduciary duty by advising me to sign a mortgage that violated the Dodd-Frank Act, Truth in Lending Act, RESPA, and Massachusetts criminal usury laws. Once a plaintiff cites a breach of fiduciary duty, the burden of proof shifts to the defendant to answer these claims, which the Housing Court was not equipped to adjudicate.
Constitutional Rights Violations:
- My constitutional rights, including due process and equal protection, were violated when the Southeastern Housing Court proceeded without proper jurisdiction, resulting in the unlawful seizure of my home. Under the Constitution, I have a right to life, liberty, and property.
- I have a right to a speedy and fair trial, which was denied and replaced by a bench trial. My discovery requests were denied due to a misapplication of law.
- I was denied the right to be heard, to call witnesses, present evidence, testify, and meet my accuser, in violation of my due process rights.
Fraud on the Court:
- In addition, under Rule *(b

Fraud on the Court:
- In addition, under Rule *(b), on November 21st, in my Verified Motion for Reconsideration and Request for Judicial Notice, I cited new evidence that Godbout Law, in addition to filing a fraudulent foreclosure deed in *, failed to claim his identity as a debt collector, an FDCPA violation. Whether I have a plausible claim or not, I have a right to be heard, to call witnesses, present evidence, testify, and meet my accuser. The Southeastern Housing Court does not have the jurisdiction to adjudicate FDCPA violations.
Judicial Notice Request:
- I request the court take judicial notice that if a person were accused of such a serious crime, they would immediately take measures to clear themselves of the accusation, especially given the gravity of fraud on the court claims. In this case, opposing counsel, while attempting to defend themselves, did so through errors and omissions. Instead of addressing the question to resolve the fraud upon the court claims, they referenced the orders and judgments from the very court whose processes they manipulated to obtain those orders. It appears that they cannot answer the question because my claims are correct and they have participated in and set in motion fraud on the court.
Conclusion:
For the reasons stated above, I respectfully request that the court grant my Verified Motion to Amend Appeal to Include Substantive Claims.
Respectfully submitted,
____________________________
Alton [Last Name]
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
Does this look good to you, or would you like any changes?

Fraud on the Court:
- In addition, under Rule *(b), on November 21st, in my Verified Motion for Reconsideration and Request for Judicial Notice, I cited new evidence that Godbout Law, in addition to filing a fraudulent foreclosure deed in *, failed to claim their identity as a debt collector in violation of the FDCPA.
- Whether I have a plausible claim or not, I have the right to be heard, to call witnesses, present evidence, testify, and meet my accuser. The Southeastern Housing Court does not have the jurisdiction to adjudicate FDCPA violations.
Judicial Notice Request:
- I request the court take judicial notice that if a person were accused of such a serious crime, they would immediately take measures to clear themselves of the accusation, especially given the gravity of fraud on the court claims. In this case, opposing counsel, while attempting to defend themselves, did so through errors and omissions. Instead of addressing the question to resolve the fraud upon the court claims, they referenced the orders and judgments from the very court whose processes they manipulated to obtain those orders. It appears that they cannot answer the question because my claims are correct and they have participated in and set in motion fraud on the court.
Conclusion:
For the reasonsstated above, I respectfully request that the court grant my Verified Motion to Amend Appeal to Include Substantive Claims.
Respectfully submitted,
____________________________
Alton [Last Name]
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]