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Fraudulent Conveyance Legal Battle
Summary
The case involves fraudulent conveyance claims under Massachusetts law, where the plaintiff was deceived into signing documents that led to unauthorized property transfers. The Housing Court lacks jurisdiction over these claims, as affirmed by the Supreme Judicial Court. The fraudulent actions include securities fraud and self-dealing by financial advisors, resulting in mortgage fraud. The case also involves usury violations with interest rates exceeding legal limits. The plaintiff seeks to have the case moved to the District Court of Massachusetts, which has appropriate jurisdiction, to address these issues and secure relief.Full Conversation
- Tiernan and Fagan made me sign Note and Mortgage for funds I never received nor owed, which constitutes fraudulent self-dealing. they didnt "make me' I was both induced and tricked . I was told that if i didnt sign the permission papers i would lose my home to an upcoming foreclsoure, though I held over $*,* in eguity with other remedies. EVIDENCE OF FRAUD IN THE EXECUTION:
*. Fraudulent Signing:
It appears you have a strong potential case for fraud. Massachusetts law under the Uniform Fraudulent Transfer Act (G.L.c. 109A) might be relevant here.
- Fraudulent inducement could form the basis of a claim.
- The Fair Debt Collection Practices Act (FDCPA) may also provide grounds for action.
Have you consulted with an attorney regarding this matter yet?
- Fraudulent inducement could form the basis of a claim.
- The Fair Debt Collection Practices Act (FDCPA) may also provide grounds for action.
Have you consulted with an attorney regarding this matter yet?
Please revise to a clear section - In *-*, Plaintiff was deceived into signing documents by her long-term advisor and three other parties: James Tiernan, Richard Fagan, and Pensco Trust Company (custodian in an IRA). The terms and conditions were misrepresented.
- In *, Plaintiff’s divorce decree awarded her the property free from mortgage payments for four years, making it unreasonable for her to sign for a debt in * that she did not owe.
- Plaintiff was coerced by her advisor, who claimed she was in a heated emergency and would lose the property to foreclosure if she did not sign the documents, despite Plaintiff having $*,* in equity in the property. She could have paid the original creditor $*,*, the amount owed by James.
Sure, here’s a clearer version:
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In *-*, Plaintiff was deceived into signing documents by her long-term advisor and three other parties: James Tiernan, Richard Fagan, and Pensco Trust Company (custodian in an IRA). The terms and conditions were misrepresented.
- In *, Plaintiff’s divorce decree awarded her the property free from mortgage payments for four years, making it unreasonable for her to sign for a debt in * that she did not owe.
- Plaintiff was coerced by her advisor, who claimed she was in a heated emergency and would lose the property to foreclosure if she did not sign the documents, despite having $*,* in equity in the property. She could have paid the original creditor $*,*, the amount owed by James.
- Plaintiff’s advisor charged her a $*,* invoice, which was financed into the loan for services never received. This increased the interest rate from *% to *%.
- The loan, a hard money loan due in 18 months, had an *% interest rate that increased to *%, violating Massachusetts usury laws.
- Truth in Lending and RESPA violations further invalidate the contract.
-Similar to *Kight v. Miller*, where the court found a genuine issue of material fact regarding fraud in the execution, Plaintiff presents evidence of being tricked into signing documents she did not intend to sign and were not in her best interest.
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Have you consulted with an attorney regarding this matter yet?
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In *-*, Plaintiff was deceived into signing documents by her long-term advisor and three other parties: James Tiernan, Richard Fagan, and Pensco Trust Company (custodian in an IRA). The terms and conditions were misrepresented.
- In *, Plaintiff’s divorce decree awarded her the property free from mortgage payments for four years, making it unreasonable for her to sign for a debt in * that she did not owe.
- Plaintiff was coerced by her advisor, who claimed she was in a heated emergency and would lose the property to foreclosure if she did not sign the documents, despite having $*,* in equity in the property. She could have paid the original creditor $*,*, the amount owed by James.
- Plaintiff’s advisor charged her a $*,* invoice, which was financed into the loan for services never received. This increased the interest rate from *% to *%.
- The loan, a hard money loan due in 18 months, had an *% interest rate that increased to *%, violating Massachusetts usury laws.
- Truth in Lending and RESPA violations further invalidate the contract.
-Similar to *Kight v. Miller*, where the court found a genuine issue of material fact regarding fraud in the execution, Plaintiff presents evidence of being tricked into signing documents she did not intend to sign and were not in her best interest.
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Have you consulted with an attorney regarding this matter yet?
*. Advisor’s Charges:
- Plaintiff’s advisor charged her a $*,* invoice, which was financed into the loan for services never received. in addition this constuites an intereest payment therby increasing the already high cost loan from an *% interest rate to *% interst rate as * + * ( the percentage of increase on the overall debt) = * % interest.
*. Usury and Other Violations:
- The loan, a hard money loan due in 18 months, had an *% interest rate that increased to *% after including the $*,* broker fee, violating Massachusetts usury laws.
- Truth in Lending and RESPA violations further underscore the contract's invalidity.
- Similar to *Kight v. Miller*, where the court found a genuine issue of material fact regarding fraud in the execution, Plaintiff presents evidence of being tricked into signing documents she did not intend to sign and were not in her best interest to do so.- In *-
It seems you have a strong case for fraud and usury violations under Massachusetts law. Here’s a brief summary:
- Fraudulent Inducement: You were tricked into signing documents that you did not intend to sign, a potential violation of the Uniform Fraudulent Transfer Act.
- Usury: The interest rate increase from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These add to the contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
- Fraudulent Inducement: You were tricked into signing documents that you did not intend to sign, a potential violation of the Uniform Fraudulent Transfer Act.
- Usury: The interest rate increase from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These add to the contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
*, Plaintiff was deceived into signing documents by her long-term advisor and three other parties: James Tiernan, Richard Fagan, and Pensco Trust Company (custodian in an IRA). The terms and conditions were misrepresented.
- In *, Plaintiff’s divorce decree awarded her the property free from mortgage payments for four years, making it unreasonable for her to sign for a debt in * that she did not owe.
- Plaintiff was coerced by her advisor, who claimed she was in a heated emergency and would lose the property to foreclosure if she did not sign the documents, despite Plaintiff
It seems you have a strong potential case for fraud and other financial violations. Here’s a brief summary:
- Fraudulent Inducement: You were tricked into signing documents you did not intend to sign.
- Usury: The interest rate increase from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These add to the contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
- Fraudulent Inducement: You were tricked into signing documents you did not intend to sign.
- Usury: The interest rate increase from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These add to the contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
having $*,* in equity in the property. She could have paid the original creditor $*,*, the amount owed by James.
*. Advisor’s Charges:
- Plaintiff’s advisor charged her a $*,* invoice, which was financed into the loan for services never received. in addition this constuites an intereest payment therby increasing the already high cost loan from an *% interest rate to *% interst rate as * + * ( the percentage of increase on the overall debt) = * % interest.
*. Usury and Other Violations:
- The loan, a hard money loan due in 18 months, had an *% interest rate that increased to *% after including the $*,* broker fee, violating Massachusetts usury laws.
.
It seems you have a strong potential case for fraud, usury, and other violations. Here’s a brief summary:
- Fraudulent Inducement: Tricked into signing documents under false pretenses (Uniform Fraudulent Transfer Act).
- Usury: Interest rate hike from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: Add to contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
- Fraudulent Inducement: Tricked into signing documents under false pretenses (Uniform Fraudulent Transfer Act).
- Usury: Interest rate hike from *% to *% likely violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: Add to contract's invalidity.
Have you documented all evidence and communications with the advisor and parties involved?
- Truth in Lending and RESPA violations further underscore the contract's invalidity.
- Similar to *Kight v. Miller*, where the court found a genuine issue of material fact regarding fraud in the execution, Plaintiff presents evidence of being tricked into signing documents she did not intend to sign and were not in her best interest to do so
It looks like you have a robust case for fraudulent inducement, usury, and other violations under Massachusetts law. Here's a concise summary:
- Fraudulent Inducement: Misled into signing documents you didn't intend to (Uniform Fraudulent Transfer Act, G.L.c. 109A).
- Usury: Interest rate increased from *% to *%, likely violating Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These further invalidate the contract.
Have you gathered and documented all the evidence and communications with the involved parties?
- Fraudulent Inducement: Misled into signing documents you didn't intend to (Uniform Fraudulent Transfer Act, G.L.c. 109A).
- Usury: Interest rate increased from *% to *%, likely violating Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These further invalidate the contract.
Have you gathered and documented all the evidence and communications with the involved parties?
i am wring a motion for reconsideration I respectfully request the Court to reconsider its previous ruling due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing Ryan v. Kehoe, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
It seems you have a strong potential case for fraud, usury, and other violations. Here's a concise summary for your motion for reconsideration:
- Fraudulent Inducement: Deceived into signing documents you did not intend to sign.
- Usury: Interest rate increase from *% to *% violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These further invalidate the contract.
Have you documented all evidence and communications with the advisor and parties involved?
- Fraudulent Inducement: Deceived into signing documents you did not intend to sign.
- Usury: Interest rate increase from *% to *% violates Massachusetts usury laws.
- Truth in Lending and RESPA Violations: These further invalidate the contract.
Have you documented all evidence and communications with the advisor and parties involved?
Yes. I would like help polishing this motion for right now. I think I need to add dates here:Introduction and Background
I respectfully request the Court to reconsider its previous ruling from august *, * to its most recent orderr affirming Plaintiff L & S Realty LLC'S Motion to Strike Defendendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
Certainly! Here's a polished version of your motion with the added dates:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the UniformFraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
Conclusion
Given the lack of subject matter jurisdiction and the new evidence of fraudulent conveyance, I respectfully request the Court to reconsider its previous ruling.
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Have you documented all evidence and communications with the advisor and parties involved?
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the UniformFraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
Conclusion
Given the lack of subject matter jurisdiction and the new evidence of fraudulent conveyance, I respectfully request the Court to reconsider its previous ruling.
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Have you documented all evidence and communications with the advisor and parties involved?
Do you think I should add this?*. Intentional Deception and Fraud:
- The opposing counsel intentionally deceived the court by assisting the all parties conspiring in filing a fabricated foreclosure deed.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
Your additions seem relevant and could strengthen your case. Here's a concise summary:
*. Intentional Deception and Fraud:
- Opposing counsel deceived the court with a fabricated foreclosure deed.
*. Aiding and Abetting Usury:
- Foreclosure deed supported usury (interest rates *.*%-*.*%), violating Chapter *, Section *.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud’s rulings supported the usurious loan.
Would you like help refining these points further?
*. Intentional Deception and Fraud:
- Opposing counsel deceived the court with a fabricated foreclosure deed.
*. Aiding and Abetting Usury:
- Foreclosure deed supported usury (interest rates *.*%-*.*%), violating Chapter *, Section *.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud’s rulings supported the usurious loan.
Would you like help refining these points further?
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain, especially as the Petitioner is living on only $* per month from Social Security
Adding the points about constitutional rights and financial harm could strengthen your motion. Here's a polished version with your additional points:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
*. Intentional Deception and Fraud:
- Opposing counsel intentionally deceived the court with a fabricated foreclosure deed.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
*. Intentional Deception and Fraud:
- Opposing counsel intentionally deceived the court with a fabricated foreclosure deed.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *
only send from section * onward
James Tiernan and Richard Fagan
Phone: Not provided
Address: Not provided
Website: Not provided
Have you consulted with an attorney regarding this matter yet?
only send from section * onward
Certainly! Here is the information from Section * onward:
Phone:(*) *-*
Address: * Mountainview Blvd, Basking Ridge, NJ *
Website: www.test.com
Would you like help refining these points further?
San Bernardino County Superior Court
Phone:(*) *-*
Address: * Mountainview Blvd, Basking Ridge, NJ *
Website: www.test.com
Would you like help refining these points further?
no tthat a mistake. Thats not my case. Please now send me from "*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *" onward
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum, leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain,especially as the Petitioner is living on only $* per month from Social Security.
Would you like any further assistance with your motion for reconsideration?
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum, leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain,especially as the Petitioner is living on only $* per month from Social Security.
Would you like any further assistance with your motion for reconsideration?
no that is a mistake. Thats not my case. Please now send me from "*. Aiding and Abetting Usury: - The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *" onward
Sure, here's the information from Section * onward:
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*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum, leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain, especially as the Petitioner is living on only $* per month from Social Security.
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Would you like further assistance with refining or expanding on any of these points?
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*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum, leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain, especially as the Petitioner is living on only $* per month from Social Security.
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Would you like further assistance with refining or expanding on any of these points?
see above
Sure, here is the refined section from point * onward:
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*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain, especially as the Petitioner is living on only $* per month from Social Security.
---
Would you like any more assistance with your motion or any other legal matter?
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*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain, especially as the Petitioner is living on only $* per month from Social Security.
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Would you like any more assistance with your motion or any other legal matter?
This motion respectfully requests reconsideration of the Honorable Judge Michaud's decision to affirm Plaintiff L&S Realty LLC's Motion to strike Defendant Karen Merritt's appeal. is lack of subject matter jurisdiction and New evidence of fruadulent converyance included in these legal arguments or a start of a new section?*. Misrepresentation of Facts:
- The judge's statement that the appeal concerns issues previously litigated is a misrepresentation. Karen Merritt's appeal focuses on fraud on the court, which has never been adjudicated.
*. Fraud on the Court:
- Substantial evidence of fraud on the court, including a fabricated foreclosure deed and usurious interest rates, was not considered.
*. Procedural Errors:
The judge's decision to threaten barring future motions without legal authority is a significant procedural error.
It seems like your arguments about lack of subject matter jurisdiction and new evidence of fraudulent conveyance would be included in the same section as part of your overall argument for reconsideration. Here’s how you can structure and integrate these points:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at7 Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Misrepresentation of Facts: The judge's statement that the appeal concerns issues previously litigated is a misrepresentation. Karen Merritt's appeal focuses on fraud on the court, which has never been adjudicated.
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
- **Fraud on the
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisor, James Tiernan, and Richard Fagan deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at7 Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Tiernan and Fagan, under the FDCPA, borrowed $*,* from Pensco Trust Company to purchase my ex-husband's debt and a car loan debt.
Evidence of Fraud in the Execution:
- Misrepresentation of Facts: The judge's statement that the appeal concerns issues previously litigated is a misrepresentation. Karen Merritt's appeal focuses on fraud on the court, which has never been adjudicated.
- Fraudulent Signing: I was induced and tricked into signing the Note and Mortgage under the pretense that they were permission papers, with threats of foreclosure despite having $*,* in equity.
- Advisor’s Charges: My advisor charged a $*,* invoice, financed into the loan for services never received, increasing the interest rate from *% to *%, violating Massachusetts usury laws.
- Usury and Other Violations: The loan's interest rate hike, Truth in Lending, and RESPA violations further underscore the contract's invalidity.
- **Fraud on the
Please revise there were * fraudlent conveyances . The orginal note and mortgaes I signed by fruad in the factum in *. Then they transferred their deed theft to plaintff in this case l & S Realty LLc on decemeber *, *. *. Newest Evidence of Fraudulent Conveyance:
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
Certainly! Here’s a revised version of your motion incorporating the fraudulent conveyances and new evidence:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received noconsideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received noconsideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
Evidence of Fraud in the Execution:
- Fraudulent Signing: I was induced and tricked into signing
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On June *, *, Godbout Law Inc. filed a complaint at MA Superior Court seeking a declaratory judgment that neither Mr. Greico nor Apponaug Business Services violated Predatory Home Loan Practices.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
Certainly! Here is the revised section with the details of the two fraudulent conveyances:
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*. Newest Evidence of Fraudulent Conveyance:
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On June *, *, Godbout Law Inc. filed a complaint at MA Superior Court seeking a declaratory judgment that neither Mr. Greico nor Apponaug Business Services violated Predatory Home Loan Practices.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegalproperty transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,*
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*. Newest Evidence of Fraudulent Conveyance:
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On June *, *, Godbout Law Inc. filed a complaint at MA Superior Court seeking a declaratory judgment that neither Mr. Greico nor Apponaug Business Services violated Predatory Home Loan Practices.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegalproperty transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,*
is this section * or a new title?Plaintiff filed an emergency Chapter * petition on August *, * (Karen Merritt vs. L & S Realty LLC, Case No. *-*) to stop the execution of possession and money judgment by the lower court. Godbout Law Inc. filed an emergency motion for relief from stay on August *, *, with fraudulent foreclosure deed and state court judgment copies that it procured by fraud on the court. On September *, *, the Court issued an order lifting the stay based on fraudulent claims, despite Plaintiff’s notice providing clear and convincing evidence of fraud. On October *, *, the court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised
It appears that you have a strong case with multiple instances of fraud, usury, and other violations. Here's a brief summary for your motion:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. Newest Evidence of Fraudulent Conveyance:
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
-- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On June *, *, Godbout Law Inc. filed a complaint at MA Superior Court seeking a declaratory judgment that neither Mr. Greico nor Apponaug Business Services violated Predatory Home Loan Practices.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to
---
Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. Newest Evidence of Fraudulent Conveyance:
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
-- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On June *, *, Godbout Law Inc. filed a complaint at MA Superior Court seeking a declaratory judgment that neither Mr. Greico nor Apponaug Business Services violated Predatory Home Loan Practices.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to
Plaintiff to return to State court to litigate the claims, despite significant reasons on the merits of the underlying claims. This was an error, as contested matters involving property rights violations and bankruptcy fraud should be transferred to the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *. This error led to the
Plaintiff's case being returned to the Southeast Housing Court, which lacks jurisdiction to adjudicate this case, resulted in the wrongful seizure of her property by the Housing Court’s .
Certainly! Here is your refined section, integrating the details:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating theUniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of us
---
Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating theUniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of us
order on October *, *. The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context
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~Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
~*. Lack of Subject Matter Jurisdiction
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
~*. New Evidence of Fraudulent Conveyance
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
~*. Constructive Fraud Allegations
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
~*. Aiding and Abetting Usury
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter
see above
*. Aiding and Abetting Usury:
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain,especially as the Petitioner is living on only $* per month from Social Security.
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Additional Section:
*. Procedural Errors:
- Plaintiff filed an emergency Chapter * petition on August *, * (Karen Merritt vs. L & S Realty LLC, Case No. *-*) to stop the execution of possession and money judgment by the lower court. Godbout Law Inc. filed an emergency motion for relief from stay on August *, *, with fraudulent foreclosure deed and state court judgment copies that it procured by fraud on the court.
- On September *, *, the Court issued an order lifting the stay based on fraudulent claims, despite Plaintiff’s notice providing clear and convincing evidence of fraud. On October *, *, the court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised Plaintiff to return to State court to litigate the claims.
- This was an error, as contested matters involving property rights violations and bankruptcy fraud should be transferred to the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *. This error led to the Plaintiff
- The fabricated foreclosure deed was used to aid and abet the lender in committing the crime of usury in violation of Chapter *, Section *, with interest rates ranging from *.*% to *.*%, far exceeding the legal limit of *% per annum leading to a fraudulent transfer.
*. Direct Involvement in Usurious Lending Practice:
- Judge Michaud, by continuing to preside over the case and dismissing counterclaims that highlighted the usurious nature of the loan, is directly involved in the usurious lending practice.
*. Violation of Constitutional Rights:
- The actions of the opposing counsel and the lender, supported by Judge Michaud’s rulings, led to the wrongful seizure of Petitioner’s property on October *, *, violating her constitutional rights to due process and equal protection under the law.
*. Financial Harm:
- The wrongful seizure of property has caused significant financial hardship, including a loss of $*,* per month in rental income and an overall financial loss of approximately $*.* million.
- The delay in addressing these issues exacerbates the financial strain,especially as the Petitioner is living on only $* per month from Social Security.
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Additional Section:
*. Procedural Errors:
- Plaintiff filed an emergency Chapter * petition on August *, * (Karen Merritt vs. L & S Realty LLC, Case No. *-*) to stop the execution of possession and money judgment by the lower court. Godbout Law Inc. filed an emergency motion for relief from stay on August *, *, with fraudulent foreclosure deed and state court judgment copies that it procured by fraud on the court.
- On September *, *, the Court issued an order lifting the stay based on fraudulent claims, despite Plaintiff’s notice providing clear and convincing evidence of fraud. On October *, *, the court granted the trustee's motion to dismiss the Chapter * case without prejudice. Judge Panos advised Plaintiff to return to State court to litigate the claims.
- This was an error, as contested matters involving property rights violations and bankruptcy fraud should be transferred to the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *. This error led to the Plaintiff
Should this be the conclusion and relief requested section? The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Yes, the conclusion and relief requested section you've written is appropriate. Here’s a polished version:
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § *, and the new evidence of fraudulent conveyance under G.L.c. 109A necessitate reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the riseof bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court facilitates the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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Would you like any further assistance with your motion or other legal matters?
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § *, and the new evidence of fraudulent conveyance under G.L.c. 109A necessitate reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the riseof bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court facilitates the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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Would you like any further assistance with your motion or other legal matters?
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C.§ *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
Yes, this section should indeed serve as your conclusion and relief requested. It summarizes the key points and requests the necessary judicial remedy. Here's a polished version:
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C.§ *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C.§ *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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In addition should I reitieriate that the suprme Judical court affirmed that fraudlant conveyances under G.L.c. 109A concluded that the Legislature did not inlude fruadlent conveyances actions, whther not statutory or under 109A within the jurisdcition of the Housing court therfore karen Merritts preys ..
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Yes, reiterating that the Supreme Judicial Court affirmed that fraudulent conveyances under G.L.c. 109A are not within the jurisdiction of the Housing Court strengthens your argument. Here’s a revised conclusion and relief requested section:
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § *, and the new evidence of fraudulent conveyance under G.L.c. 109A necessitate reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *.
Reiterating that the Supreme Judicial Court affirmed that fraudulent conveyances under G.L.c. 109A are not within the jurisdiction of the Housing Court further strengthens this argument.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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Yes, reiterating that the Supreme Judicial Court affirmed that fraudulent conveyances under G.L.c. 109A are not within the jurisdiction of the Housing Court strengthens your argument. Here’s a revised conclusion and relief requested section:
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § *, and the new evidence of fraudulent conveyance under G.L.c. 109A necessitate reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C. § *(d) and * U.S.C. § *.
Reiterating that the Supreme Judicial Court affirmed that fraudulent conveyances under G.L.c. 109A are not within the jurisdiction of the Housing Court further strengthens this argument.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court to affirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
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see above
It seems you're working on a comprehensive and detailed motion for reconsideration. Here’s a polished version incorporating all your points and adding the conclusion and relief requested section:
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
***.
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Introduction and Background
I respectfully request the Court to reconsider its previous ruling from August *, *, to its most recent order affirming Plaintiff L & S Realty LLC's Motion to Strike Defendant Karen Merritt's Appeal due to a lack of subject matter jurisdiction and new evidence that has come to light.
*. Lack of Subject Matter Jurisdiction:
- Under General Laws c. 185C, § *, the Housing Court does not have jurisdiction to adjudicate claims under G.L.c. 109A, which pertains to fraudulent transfers.
- Referencing *Ryan v. Kehoe*, * Mass. * (*), the Supreme Judicial Court determined that the Housing Court lacks jurisdiction in such matters.
*. New Evidence of Fraudulent Conveyance:
- In *, my financial advisors, James Tiernan and Richard Fagan, deceived me into signing documents that I believed were "permission papers." These were actually a Note and two mortgages on my properties at * Brayton Woods, Rehoboth, and * Oak Street, Norton, MA.
- I received no consideration for this transfer, violating the Uniform Fraudulent Transfer Act, G.L.c. 109A.
- Debt collectors posing as creditors facilitated an illegal transfer of property without providing fair consideration to Karen Merritt (debtor).
- Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud.
- With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor.
- On November *, *, Peter Fallon signed a Certificate of Organization as a limited liability company in the Commonwealth of Massachusetts to form L & S Realty, LLC. This filing preceded the fraudulent transfer.
- On May *, *, the foreclosure deed was transferred to L & S Realty, LLC.
*. Constructive Fraud Allegations:
- The illegal property transfer constitutes a fraudulent conveyance under G.L.c. 109A.
- The actions of the involved parties demonstrate a clear intent to defraud the creditor, Karen Merritt.
***.
see above
Certainly! Here's the polished conclusion and relief requested section:
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C.§ *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court toaffirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
Furthermore, the Supreme Judicial Court has affirmed that fraudulent conveyances under G.L.c. 109A concluded that the Legislature did not include fraudulent conveyance actions, whether statutory or under 109A, within the jurisdiction of the Housing Court. Therefore, Karen Merritt prays...
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Conclusion and Relief Requested
The Housing Court’s lack of jurisdiction under General Laws c. 185C, § * and the new evidence of fraudulent conveyance under G.L.c. 109A necessitates reconsideration. Specifically, James Tiernan and Richard Fagan, custodians of Pensco Trust Company, engaged in securities fraud and self-dealing to commit mortgage fraud. With the assistance of Blake Godbout Law Inc., the property was transferred to L&S Realty LLC in an attempt to hinder, delay, or defraud Karen Merritt, the creditor. As the debtor, Karen Merritt is owed fair consideration, making her the creditor in this context.
Additionally, the fraudulent transfer and fraud on the court have given rise to bankruptcy fraud, which falls under the jurisdiction of the District Court of Massachusetts under * U.S.C.§ *(d) and * U.S.C. § *.
Given the lack of subject matter jurisdiction of the Housing Court under General Laws c. 185C, § *, the new evidence of fraudulent conveyance under G.L.c. 109A, and the rise of bankruptcy fraud, I respectfully request this Court toaffirm my constitutional right to relief. Therefore, I pray that the Court affirms an easy transition for the removal of this case to the District Court of Massachusetts, which has the appropriate jurisdiction under * U.S.C. § *(d) and * U.S.C. § *.
Furthermore, the Supreme Judicial Court has affirmed that fraudulent conveyances under G.L.c. 109A concluded that the Legislature did not include fraudulent conveyance actions, whether statutory or under 109A, within the jurisdiction of the Housing Court. Therefore, Karen Merritt prays...
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