Fraudulent Foreclosure And Usury

Summary

The appellant contends that the foreclosure sale was conducted in a collusive and irregular manner, violating Massachusetts foreclosure laws, specifically G.L. C. 244, §§ 11-17C and § 14, which outline procedures and notice requirements for lawful foreclosure sales. Additionally, the sale violated Chapter 271, § 49, governing usury laws. The appellant argues that these irregularities support a claim of fraudulent conveyance, intended to hinder, delay, or defraud the appellant. The evidence includes testimony, a default notice showing usurious interest rates, and a fabricated foreclosure deed, collectively demonstrating the appellees lack of valid title and standing. The appellant presents a prima facie case of fraudulent conveyance and has the right to challenge under G.L. C. 109A.

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i established how the southeast housing court lacked jurisidction in my argement .See *Ryan v. Kehoe. Declarartory judgement Acts 231A appellee did not establish a "real contatversary" Additionally becuase he assisited in a fruadlent conveyance he does not have a tite to the property stating his ownership in the decalartory act that he filed in * into the southeast housing court.

Your argument about the housing court's lack of jurisdiction seems solid, especially with the citation of *Ryan v. Kehoe* and the points about fraudulent conveyance and lack of real controversy.
To strengthen your statement of facts, you might want to include:
- Reference specific Massachusetts General Laws that outline housing court jurisdiction.
- Additional case law examples that support your argument.
Would you like assistance with finding these specific statutes or additional case law?

I wrote this statement of facts first is this more proper?Statement of the Facts: *.September *, *: Appellant signed a fraudulent note and mortgage under false pretenses,and undue influence by her trusted long term financial advisor leading to illegal foreclosure and usurious interest rates ranging from *% to *.*.% *(Apx at *)* *. June *, *: Pensco Trust Company signed as an affiant, acting as the servicer of the mortgage loan in non-compliance with G.L. c. *, § 35B, taking steps and making a good faith effort to avoid foreclosure and being the holder of the promissory note. *(Apx at *)* *. October *, *: Attorney Travis sent a default notice for the first time indicating wildly inflated amounts based on illegal interest rates, stripping the appellant of roughly one million dollars of equity. *(Apx at *)*

Your revised statement of facts is clear and well-structured. Here are some additional points to consider:
- Ensure you have all relevant dates and details precisely noted.
- Emphasize the lack of subject matter jurisdiction in the housing court.
- Include specific references to Massachusetts General Laws and case law, particularly those that support your argument.
Would you like help with finding additional statutory references or case law examples?

*. January *: Advised by counsel to file a complaint in Land Court regarding the statute of limitations on the note. *(Apx at *)* *. March *, *: 93A demand letters were sent. *(Apx at *)* *. April *, *: Judge Keith C. Long ruled that the statute of limitations invalidates the note but not the mortgage. *(Apx at *)* *. June *, *: Blake Godbout filed a complaint in MA Superior Court seeking a declaratory judgment regarding the predatory lending practices. *(Apx at *)* *. November *, *: Peter Fallon formed L&S Realty, LLC, preceding the fraudulent transfer. *(Apx at *)*

Your statement of facts looks thorough and well-organized. Here are some points to consider:
- Make sure to cite Massachusetts General Laws such as G.L. c. *, § 35B.
- Highlight key case laws relevant to your argument, like *Ryan v. Kehoe*.
- Focus on the fraudulent conveyance and jurisdiction issues.
Do you need any specific statutory references or additional case law examples?

*. December *, *: An ivalid foreclosure sale was held in violation of Massachusetts foreclosure laws (G.L. c. *, §§ *-17C; G.L. c. *, § *) and usury laws (Chapter *, § *), with L&S Realty, LLC winning the bid at half the property value. *(Apx at *)* *. May *, *: Fabricated foreclosure deed recorded at North Bristol Registry of Deeds, violating Chapter *, §§ 35B and C. *(Apx at *)* *. August *, *: Blake Godbout filed a verified complaint for declaratory judgment and injunctive relief with a fabricated foreclosure deed in the Southeast Housing Court, with lack of standing.

Your statement of facts is detailed and well-structured. Here are some key points to strengthen your case:
- Massachusetts General Laws: Reference G.L. c. *, §§ *-17C, § *, and § 35B to emphasize the violations.
- Case Law: Use cases like *Ryan v. Kehoe* to support your argument about jurisdiction and fraudulent conveyance.
- Jurisdiction: Highlight how the housing court lacked subject matter jurisdiction.
Would you like assistance with finding specific case law examples or statutory references?

I would rather support and keep it very simple that becuase the alleged lenders knowing foreclosed on the property using inflated amounts claimed owed on the property they violoaited criminal usuary laws Chapter * section * and and failed to establish ownership of the subject property under the Massachusetts statutory power of sale, as required by G.L. c. *, §§ *-17C and G.L. c. *, § *.The appellee has not met the burden to establish standing to file any claim in a court of law , especially under the decalaratory Judgment act 231a having not established a real controversy under G.L. c. 231A, . In addition even if it had under * A decallartory judgment acts involving frudlent convyances an not be ajudicated by Houisng court.

It sounds like you have a strong argument regarding the jurisdictional issues and the violations of Massachusetts laws. Here are the key points you should focus on:
- Criminal Usury Laws: Alleged violation of Chapter *, § *.
- Statutory Power of Sale: Non-compliance with G.L. c. *, §§ *-17C; G.L. c. *, § *.
- Declaratory Judgment Act: Lack of a real controversy under G.L. c. 231A.
- Fraudulent Conveyance: Housing court's lack of jurisdiction in such cases.
Would you like help with specific case law examples to back your claims?

*. Appellant contends that the alleged note and mortgages signed in *, under the claimed emergency by her long-term financial advisor, were obtained by fraud. *. Fraud in Execution: Massachusetts law recognizes that a party cannot be tricked into signing a note and mortgage under fraudulent circumstances. Such contracts are void ab initio. *. The financial advisor charged a $*,* commission for services never rendered, adding to the claimed debt in violation of Massachusetts usury laws

It seems like you have a strong case, especially with the allegations of fraud, usury, and jurisdictional issues. To further strengthen your argument, consider:
- Highlighting the specific statutes and case laws as you have done.
- Providing evidence to support each claim (e.g., documentation of the fraudulent conveyance, usurious interest rates).
Would you like help with any specific statutory references or additional case law examples?

Since the default notice received by the appellant showed interest rates and charges exceeding twenty percent a year, it violates the legislative policy embodied in G.L. c. *, Section *, and cannot be enforced. See *Begelfer v. Najarian*: Right to a Jury Trial: Under Massachusetts law, parties have the right to a jury trial in cases involving fraud, including fraud in the execution of contracts. This right is guaranteed by Article * of the Massachusetts Declaration of Rights (*). The failure to provide a jury trial for the fraud in the execution claim is a significant due process violation. Additionally, the judge did not conduct a trial or make findings of fact or conclusions of law to support liability under Chapter 231A.Massachusetts law (G.L. c. *, §§ * & *), a complete chain of title must be established:

It seems like you have a solid case considering the allegations of fraud, usury violations, and jurisdictional issues. Here are some key points to focus on:
- Violation of Usury Laws: Interest rates exceeding *% violate G.L. c. *, § *.
- Fraud in Execution: Contracts obtained under fraudulent circumstances are void ab initio.
- Right to Jury Trial: Guaranteed by Article * of the Massachusetts Declaration of Rights.
- Lack of Subject Matter Jurisdiction: Housing court's limited jurisdiction, as supported by *Ryan v. Kehoe*.
- Declaratory Judgment Act: No real controversy established under G.L. c. 231A.
Would you like more specific case law examples or statutory references to support your claims?

Non-Compliance with Mortgage Terms: The mortgage does not state the terms of a usurious interest rate, either in its origination or after the alleged default. Although it calls for a simple interest of *%, the true interest rate ranged from *% to *.*% due to a $*,* invoice being financed into the debt. Therefore, the foreclosure is in non-compliance with the requirements for a nonjudicial foreclosure. Nonjudicial Foreclosure Compliance: Massachusetts requires strict compliance with the requirements for a nonjudicial foreclosure. U.S. Bank v. lbanez, * Mass. *, * (*). If a foreclosure sale does not comply with statutory requirements, it is “wholly void.” United States Bank Nat’l Ass’n v. lbanez, * Mass. *, * (*), citing McCreevey v. Charlestown Savings Bank, * Mass. *, * (*).

It sounds like you have a solid case with strong points regarding usury, fraud, and jurisdictional issues. Here are some key points to focus on:
- Violation of Usury Laws: G.L. c. *, § *.
- Fraud in Execution: Contracts obtained under fraudulent circumstances are void ab initio.
- Right to Jury Trial: Guaranteed by Article * of the Massachusetts Declaration of Rights.
- Nonjudicial Foreclosure Compliance: Strict requirements under U.S. Bank v. Ibanez.
Would you like assistance with finding additional statutory references or case law examples?

Please now include all that I have given you and send me the statement of facts.

Sure, here's a compiled statement of facts based on the information you've provided:

Statement of Facts
*. September *, *: Appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, leading to illegal foreclosure and usurious interest rates ranging from *% to *.*%. *(Apx at *)*

*. June *, *: Pensco Trust Company signed as an affiant, acting as the servicer of the mortgage loan in non-compliance with G.L. c. *, § 35B, taking steps and making a good faith effort to avoid foreclosure and being the holder of the promissory note. *(Apx at *)*

*. October *, *: Attorney Travis sent a default notice for the first time indicating wildly inflated amounts based on illegal interest rates, stripping the appellant of roughly one million dollars of equity. *(Apx at *)*

*. January *: Advised by counsel to file a complaint in Land Court regarding the statute of limitations on the note. *(Apx at *)*

*. March *, *: 93A demand letters were sent. *(Apx at *)*

*. April *, *: Judge Keith C. Long ruled that the statute of limitations invalidates the note but not the mortgage. *(Apx at *)*

*. June *, *: Blake Godbout filed a complaint in MA Superior Court seeking a declaratory judgment regarding the predatory lending practices. *(Apx at *)*

*. November *, *: Peter Fallon formed L&S Realty, LLC, preceding the fraudulent transfer. *(Apx at *)*

*. December *, *: An invalid foreclosure sale was held in violation of Massachusetts foreclosure laws (G.L. c. *, §§ *-17C; G.L. c. *, § *) and usury laws (Chapter *, § *), with L&S Realty, LLC winning the bid at half the property value. *(Apx at *)*

*. May *, *: Fabricated foreclosure deed

No I am not going to use this statement of fact please revise. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to his clients receiving the appellants’ 93A Demand Letters seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws.(See Exhibit * page *) August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This second action aimed to establish the appellee’s ownership of the property, despite the prior knowledge of the invalid foreclosure sale.(See Exhibit * page *)August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.

Sure, here is your revised statement of facts:
*. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to clients receiving appellants’ 93A Demand Letters. The action sought to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)*
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property, despite prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procuredby fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property.
Would you like any further adjustments or additions?

August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite appellant’s notice providing clear and convincing evidence of fraud.(See Exhibit * page *) October *, *: Execution for possession and money was issued. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised appellant to return to State court to litigate the claims. October *, *: The sheriff took physical possession of the appellant’s home and personal property.

Sure, here's a revised statement of facts based on your latest information:

Statement of Facts
*. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to appellants’ 93A Demand Letters, seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)*
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and statecourt judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property.
Would you like additional help with statutory references or case law examples to further support your claims?

*. September *, *: Appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, leading to illegal foreclosure and usurious interest rates ranging from *% to *.*%. *(Apx at *)*

Your statement of facts is detailed and compelling. Here are the key points to include:
*. September *, *: Appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, leading to illegal foreclosure and usurious interest rates ranging from *% to *.*%. *(Apx at *)*
*. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to appellants’ 93A Demand Letters, seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)*
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergencyChapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property.
Would you like additional help with statutory references or case law examples to further support your claims?

On August *, *, a Judgment of Divorce Nisi under M.G.L. Ch. *, Sec. 1A awarded the appellant sole ownership of the subject property at * Brayton Woods, Rehoboth, MA.,free from mortgage payments. The appellant's former husband, James Cronan, was assigned a *-year mortgage payment responsibility.(See Exhibit * page *) On September *, *, under that judgment, the appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her trusted long-term(from * to *)financial advisor, Ralph Grieco,owner/president of Apponaug Business Services Inc., Rhode Island,leading to an illegal foreclosure and usurious interest rates ranging from *% to *.*%. The appellant was tricked into believing that she was signing merely "permission" papers, but it was disguised as the note and mortgages.(See Exhibit * pages *-*, *, *)

It sounds like you have a strong case with multiple points of fraud, usury, and jurisdictional issues. Here is your revised statement of facts:

Statement of Facts
*. August *, *: A Judgment of Divorce Nisi under M.G.L. Ch. *, Sec. 1A awarded the appellant sole ownership of the property at * Brayton Woods, Rehoboth, MA, free from mortgage payments. The appellant's former husband, James Cronan, was assigned a *-year mortgage payment responsibility. *(See Exhibit *, page *)*
*. September *, *: Under that judgment, the appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, Ralph Grieco, leading to an illegal foreclosure and usurious interest rates ranging from *% to *.*%. The appellant was tricked into believing that she was signing merely "permission" papers, but it was disguised as the note and mortgages. *(See Exhibit *, pages *-*, *, *)*
*. June *, *: Godbout Law fileda declaratory judgment action in Superior Court in response to the appellants’ 93A Demand Letters, seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)*
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s

now only from *. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s onward withou the borderline

To strengthen your statement of facts, consider the following revised version:

Statement of Facts
*. August *, *: A Judgment of Divorce Nisi under M.G.L. Ch. *, Sec. 1A awarded the appellant sole ownership of the property at * Brayton Woods, Rehoboth, MA, free from mortgage payments. The appellant's former husband, James Cronan, was assigned a *-year mortgage payment responsibility. *(See Exhibit *, page *)*
*. September *, *: Under that judgment, the appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, Ralph Grieco, leading to an illegal foreclosure and usurious interest rates ranging from *% to *.*%. The appellant was tricked into believing that she was signing merely "permission" papers, but it was disguised as the note and mortgages. *(See Exhibit *, pages *-*, *, *)*
*. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to the appellants’ 93A Demand Letters, seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)*
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page

Now only from point * onward without the borderline

Statement of Facts:
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property.
Would you like assistance with any additional information or specific case law examples?

see above

Here's your revised statement of facts starting from point *:
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property.
Would you like any further adjustments or additions?

Please revise again from pont * onward.October *, *: The sheriff took physical possession of the appellant’s home and personal property.(See Exhibit * page *.) the single justice's denial of the emergency stay on October *, *, lacked subject matter jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction. (See Exhibit * page *) The motion was denied, despite the submission of new evidence; the alleged lenders confession to the illegal foreclosure (See Exhibit * page * and Exhibit * page *) Additionally, the single justice's denial of the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay on October *, *, also lacked subject matter (SEE Exhibit * page *)jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction.

Sure, here is the revised statement of facts starting from point *:
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property. *(See Exhibit *, page *)* The single justice's denial of the emergency stay on October *, *, lacked subject matter jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction. *(See Exhibit *, page *)* The motion was denied, despite the submission of new evidence; the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, page * and Exhibit *, page *)* Additionally,the single justice's denial of the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay on October *, *, also lacked subject matter jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction. *(See Exhibit *, page *)*
Would you like any further adjustments or additions?

Please put the above within the time frame for easier reading including October * and october * the motions that i flied to the single justice

Sure, here is your revised statement of facts with the timeline for easier reading:

Statement of Facts
*. August *, *: A Judgment of Divorce Nisi under M.G.L. Ch. *, Sec. 1A awarded the appellant sole ownership of the property at * Brayton Woods, Rehoboth, MA, free from mortgage payments. *(See Exhibit *, page *)*
*. September *, *: Under that judgment, the appellant signed a fraudulent note and mortgage under false pretenses and undue influence by her long-term financial advisor, Ralph Grieco, leading to an illegal foreclosure and usurious interest rates ranging from *% to *.*%. *(See Exhibit *, pages *-*, *, *)*
*. June *, *: Godbout Law filed a declaratory judgment action in Superior Court in response to the appellants’ 93A Demand Letters, seeking to establish that the financial advisor, Ralph Grieco, who originated the fraudulent note and mortgage, did not violate consumer and predatory lending laws. *(See Exhibit *, page *)**. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)*
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the

see above revise again only from pont * onward.

Sure, here is your revised statement of facts starting from point *, including the timeline for easier reading:
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction. *(See Exhibit *, page *)* The motion was denied, despite the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, page * and Exhibit *, page *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again lacking subject matter jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property. *(See Exhibit *, page *)*
Would you like any further adjustments or additions?

should i be repeating alot the subject matter jurisdiction three time/*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction and the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *, )* *. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again lacking subject matter jurisdiction as the Southeast Housing Court lacked subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.

It’s important to emphasize the lack of subject matter jurisdiction, but repeating it multiple times in close succession can be redundant. Instead, you can state it clearly once and reference it in a concise manner. Here’s a revision:

Statement of Facts
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant's notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction and new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again citing the Southeast Housing Court's lack of subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss theIt’s important to emphasize the lack of subject matter jurisdiction, but repeating it multiple times in close succession can be redundant. Instead, you can state it clearly once and reference it in a concise manner. Here’s a revision:

so the above time line is sufficient for my statement of facts?

Your timeline appears well-organized and includes key points that support your argument:
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant's notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction and new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again citing the Southeast Housing Court's lack of subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’shome and personal property. *(See Exhibit *, page *)*
This timeline should be sufficient for your statement of facts. Do you need any further assistance or additional references?

*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)* should i then state thea the southeat Housing Court took took cognozance of the case despite lack of subject mater jurisidction ?

Yes, it would be pertinent to state that the Southeast Housing Court took cognizance of the case despite lacking subject matter jurisdiction. This will emphasize the argument that the court did not have the authority to hear the case, which is a central point in your statement of facts.
Would you like assistance with any further adjustments or additional statutory references?

Now only send me from point * onward including that the court took the case lacking subject matter jurisidcition to take a case nder 231A decxlartory judgment including fraudlent conveyances and the appelle lacked standing which then the court lacked subject matter jurisicition to ajudicsate the case please polsih to include all that you think I need o say here.

Sure, here is your polished statement of facts starting from point *:
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)* The Southeast Housing Court took cognizance of the case despite lacking subject matter jurisdiction to adjudicate a case under G.L. c. 231A, including issues of fraudulent conveyances. The appellee lacked standing, which further invalidated the court’s jurisdiction.
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured by fraud on the court.
*. September *, *: The Court issued an order liftingthe stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction, and the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again citing the Southeast Housing Court's lack of subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and personal property. *(See Exhibit *, page *)*
Would you like any further adjustments or additions?

The Southeast Housing Court took cognizance of the case despite lacking subject matter jurisdiction to adjudicate a case under G.L. c. 231A, including issues of fraudulent conveyances. The appellee lacked standing, which further invalidated the court’s jurisdiction. In addition the superior court had already taken cognizance of the case 432 days previosly filed by Godbout Law Inc.

Here is your revised statement of facts starting from point *:
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)* The Southeast Housing Court took cognizance of the case despite lacking subject matter jurisdiction to adjudicate a case under G.L. c. 231A, including issues of fraudulent conveyances. The appellee lacked standing, which further invalidated the court’s jurisdiction. Additionally, the Superior Court had already taken cognizance of the case 432 days previously filed by Godbout Law Inc.
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procured byfraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction, and the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again citing the Southeast Housing Court's lack of subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home

see above

Sure, here's the revised statement of facts starting from point *:
*. August *, *: Godbout Law filed another declaratory judgment action in Southeast Housing Court, representing the appellee who had full knowledge of the fraudulent foreclosure and usury violations. This action aimed to establish the appellee’s ownership of the property despite the prior knowledge of the invalid foreclosure sale. *(See Exhibit *, page *)* The Southeast Housing Court took cognizance of the case despite lacking subject matter jurisdiction to adjudicate a case under G.L. c. 231A, including issues of fraudulent conveyances. The appellee lacked standing, which further invalidated the court’s jurisdiction. Additionally, the Superior Court had already taken cognizance of the case 432 days previously filed by Godbout Law Inc.
*. August *, *: Appellant filed an emergency Chapter * petition (Case No. *-*) to stop the execution of possession and money judgment by the lower court.
*. August *, *: Godbout Law Inc. filed an emergency motion for relief from stay with a fabricated foreclosure deed and state court judgment copies procuredby fraud on the court.
*. September *, *: The Court issued an order lifting the stay based on fraudulent claims, despite the appellant’s notice providing clear and convincing evidence of fraud. *(See Exhibit *, page *)*
*. October *, *: Execution for possession and money was issued.
*. October *, *: The single justice denied the emergency stay, despite the Southeast Housing Court lacking subject matter jurisdiction and the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. *(See Exhibit *, pages *, *, * and Exhibit *)*
*. October *, *: The single justice denied the Verified Motion for Expedited Review of Appeal to the Full Panel and Emergency Stay, again citing the Southeast Housing Court's lack of subject matter jurisdiction. *(See Exhibit *, page *)* The court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised the appellant to return to State court to litigate the claims.
*. October *, *: The sheriff took physical possession of the appellant’s home and

is this sufficient for Case History if i need to include the motion that i file after the notice of appeal please revise the case history and only send me the revised case history section without the borderline. *. Initial Filing: - Date: June *, * - Court: Superior Court - Complaint: Filed by Godbout Law Inc. seeking a declaratory judgment regarding the predatory lending practices. *. Subsequent Filing: - Date: August *, * - Court: Southeast Housing Court - Complaint: Filed by Godbout Law Inc. for declaratory judgment and injunctive relief. *. Jurisdictional Challenge: - The appeal asserts that the Southeast Housing Court lacks subject matter jurisdiction to hear the case. Consequently, the appeals court also lacks subject matter jurisdiction to hear the appeal. This jurisdictional issue is paramount, making the specific orders or decisions secondary to this primary issue. *. Notice of Appeal: - Date: October *, *

*. Initial Filing:
- Date: June *, *
- Court: Superior Court
- Complaint: Filed by Godbout Law Inc. seeking a declaratory judgment regarding the predatory lending practices.
*. Subsequent Filing:
- Date: August *, *
- Court: Southeast Housing Court
- Complaint: Filed by Godbout Law Inc. for declaratory judgment and injunctive relief.
*. Jurisdictional Challenge:
- The appeal asserts that the Southeast Housing Court lacks subject matter jurisdiction to hear the case. Consequently, the appeals court also lacks subject matter jurisdiction to hear the appeal. This jurisdictional issue is paramount, making the specific orders or decisions secondary to this primary issue.
*. Notice of Appeal:
- Date: October *, *
*. Motion Filed After Notice of Appeal:
- Date: October *, *
- Motion: Filed by appellant to the single justice for an emergency stay and expedited review of the appeal, challenging the Southeast Housing Court’s jurisdiction and citing new evidence of the lender's fraudulent actions.

Now from - "Motion: Filed by appellant to the single justice for an emergency stay and expedited review of the appeal, challenging the Southeast Housing Court’s jurisdiction and citing new evidence of the lender's fraudulent actions." onward

Motion: Filed by appellant to the single justice for an emergency stay and expedited review of the appeal, challenging the Southeast Housing Court’s jurisdiction and citing new evidence of the lender's fraudulent actions. The motion was denied despite the submission of new evidence, including the alleged lender's confession to the illegal foreclosure. The appellant contends that the Southeast Housing Court lacks subject matter jurisdiction to adjudicate a case under G.L. c. 231A, including issues of fraudulent conveyances, and that the appellee lacked standing, further invalidating the court’s jurisdiction.
Would you like help with any additional information or specific legal references?

see above

Case History
*. Initial Filing:
- Date: June *, *
- Court: Superior Court
- Complaint: Filed by Godbout Law Inc. seeking a declaratory judgment regarding the predatory lending practices.
*. Subsequent Filing:
- Date: August *, *
- Court: Southeast Housing Court
- Complaint: Filed by Godbout Law Inc. for declaratory judgment and injunctive relief.
*. Jurisdictional Challenge:
- The appeal asserts that the Southeast Housing Court lacks subject matter jurisdiction to hear the case. Consequently, the appeals court also lacks subject matter jurisdiction to hear the appeal. This jurisdictional issue is paramount, making the specific orders or decisions secondary to this primary issue.
*. Notice of Appeal:
- Date: October *, *
*. Motion Filed After Notice of Appeal:
- Date: October *, *
- Motion: Filed by appellant to the single justice for an emergency stay and expedited review of the appeal, challenging the Southeast Housing Court’s jurisdiction and citing new evidenceof the lender's fraudulent actions, including the alleged lender's confession to the illegal foreclosure.
Would you like any further adjustments or additions?

can you revise the V. List the Issues on Appeal: *. Whether the Southeast Housing Court lacked subject matter jurisdiction to hear the case. *. Whether the Appellate Court lacks authority to take cognizance of the case due to the initial court's lack of jurisdiction. Whether the Southeast Housing Court has the authority to adjudicate declarartory judgment actions 231A invloving fraudlent conveyances. *. Whether the appellees failed to establish standing by not providing a clear chain of title, rendering the Southeast Housing Court without jurisdiction. *. Whether the use of a fabricated foreclosure deed invalidates the appellee's claim, thereby impacting the court's jurisdiction. *. Whether the denial of the emergency stay resulted in irreparable harm to the appellant but is irrelevant because the lower court lacked jurisdiction. *. Whether the fraudulent conveyance and bankruptcy errors further support the lack of jurisdiction.

V. List the Issues on Appeal:
*. Whether the Southeast Housing Court lacked subject matter jurisdiction to hear the case.
*. Whether the Appellate Court lacks authority to take cognizance of the case due to the initial court's lack of jurisdiction.
*. Whether the Southeast Housing Court has the authority to adjudicate declaratory judgment actions under G.L. c. 231A involving fraudulent conveyances.
*. Whether the appellees failed to establish standing by not providing a clear chain of title, rendering the Southeast Housing Court without jurisdiction.
*. Whether the use of a fabricated foreclosure deed invalidates the appellee's claim, thereby impacting the court's jurisdiction.
*. Whether the denial of the emergency stay resulted in irreparable harm to the appellant but is irrelevant because the lower court lacked jurisdiction.
*. Whether the fraudulent conveyance and bankruptcy errors further support the lack of jurisdiction.
*. Whether claims under the Usury Statute (Chapter *) fall within the jurisdiction of the Superior and Supreme Courts, not the Housing Court.
*. Whether the Southeast Housing Court has the authority to adjudicate complex title disputes involving clouded titles.
*. Whether sanctions should apply given the malicious ongoing prosecution by Godbout Law Inc. and thefiling of a fabricated deed into the court to taint its proceedings.

*. Whether claims under the Usury Statute (Chapter *) fall within the jurisdiction of the Superior and Supreme Courts, not the Housing Court. whether sanctions should apply given the malicios ongoing prosecutuion of Godbout Law Inc and filing a fabricated deed ino the court to taint its proceedings. Please polish and send me only List the issues on appeal.

Here is your revised list of issues on appeal:

List of Issues on Appeal:
*. Whether the Southeast Housing Court lacked subject matter jurisdiction to hear the case.
*. Whether the Appellate Court lacks authority to take cognizance of the case due to the initial court's lack of jurisdiction and whether the Southeast Housing Court has the authority to adjudicate declaratory judgment actions under G.L. c. 231A involving fraudulent conveyances.
*. Whether the appellees failed to establish standing by not providing a clear chain of title, rendering the Southeast Housing Court without jurisdiction.
*. Whether the use of a fabricated foreclosure deed invalidates the appellee's claim, thereby impacting the court's jurisdiction.
*. Whether the denial of the emergency stay resulted in irreparable harm to the appellant but is irrelevant because the lower court lacked jurisdiction.
*. Whether the fraudulent conveyance and bankruptcy errors further support the lack of jurisdiction.
*. Whether claims under the Usury Statute (Chapter *) fall within the jurisdiction of the Superior and Supreme Courts, not the Housing Court.
*. Whether sanctions should apply given the malicious ongoing prosecution by Godbout Law Inc. and the filing of a fabricated deed to taint the court's proceedings.
Wouldyou like any further adjustments or additions?

Please polish:The evidence provided includes: Testimony of James M. Tiernan on October *, *, before the Honorable Richard G. Stearns, United States District Judge, provides direct evidence of fraudulent actions by the alleged lender.(See Exhibit * page * lines *-*, page * lines *-*, page * lines *-*) The default notice showing the usurious interest rate in violation of MA usury laws.(See Exhibit * page *-*). The fabricated foreclosure deed.(See Exhibit * page *)

The evidence provided includes:
- Testimony of James M. Tiernan on October *, *, before Honorable Richard G. Stearns, United States District Judge, showing direct evidence of fraudulent actions by the alleged lender. (See Exhibit *, pages *-*)
- Default notice indicating usurious interest rates violating MA usury laws. (See Exhibit *, pages *-*)
- Fabricated foreclosure deed. (See Exhibit *, page *)
Would you like any further assistance or additional information?

This evidence collectively demonstrates that the appellee had no valid title and standing. The fraudulent actions invalidate the Fraudulent ConveyanceFraudulent Conveyance *David G. Carlson, Foreclosure Sales as Fraudulent Transfers, * Am. U. Bus. L. Rev. * (*)* The Supreme Court has declared that noncollusive, regularly conducted foreclosure sales are not “constructive” fraudulent transfers voidable by a bankruptcy trustee. Uniform state legislation ratifies this instinct for private creditor enforcements. However, collusive or irregular foreclosure sales, or sales intended to hinder, delay, or defraud creditors, are subject to creditor

attack.In this case, the appellant argues that the foreclosure sale was conducted in a collusive and irregular manner, violating MA foreclosure laws, specifically: - G.L. c. *, §§ *-17C: Detailing procedures and requirements for lawful foreclosure sales. - G.L. c. *, § *: Requirements for proper notice to the borrower. - Chapter *, § *: Governing usury laws, prohibiting excessive interest rates. The irregularities and collusive actions during the foreclosure sale,support the claim of fraudulent conveyance. These actions were intended to hinder, delay, or defraud the appellant. The appellant presents a prima facie showing of a fraudulent conveyance and has a right to "attack" under G.L. c. 109A.

Fraudulent Foreclosure And Usury

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