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Eleventh Circuit

Class Action Against Wells Fargo HELOC Mortgage Dismissed as a Typographical Error

These unauthorized changes allegedly constitute a criminal offense under state laws in Florida and many other states.

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Tippett v. Wells Fargo Bank, N.A.

(5:20-cv-00342)

District Court, M.D. Florida

JUNE 4, 2021 | REPUBLISHED BY LIT: JUN 8, 2021

A class-action lawsuit filed against Wells Fargo Bank NA alleging that the mortgage lender unlawfully “corrected” agreements for thousands of customers’ Wells Fargo home loan terms has now been effectively dismissed.

Plaintiffs accused Wells Fargo of altering maturity date on loans, a change they claim damages home values and marketability for mortgage holders.

The complaint was filed by Philip and Ingrid Tippett of Florida.

The Tippetts claim that Wells Fargo unlawfully changed the maturity dates on their home equity line of credit after realizing it had failed to set that loan to terminate after the mortgages’ final maturity date.

According to the class action lawsuit, failing to adjust these dates would have resulted in the debts becoming unsecured – increasing the bank’s risk that they won’t be paid.

However, rather than informing customers of the mistake so that they could authorize a change, Wells Fargo allegedly took it upon itself to unilaterally file thousands of documents meant to “correct” the maturity dates in order to make them compliment the home equity loans.

These documents are reportedly referred to by Wells Fargo as an “affidavit of correction.”

The class-action lawsuit argues that these changes damage the titles of the homes tied to the mortgages. This damage, in turn, reduces the homes’ property value and marketability, according to the complaint.

These unauthorized changes allegedly constitute a criminal offense under state laws in Michigan, Colorado, California, Florida, Pennsylvania, and possibly other states.

REPORT AND RECOMMENDATION1

Upon referral, this putative class action is before the court on Defendant Wells Fargo Bank, N.A.’s (“Wells Fargo”) motion to dismiss (Doc. 32), to which Plaintiffs have responded (Doc. 37). Wells Fargo filed a reply (Doc. 39), and Plaintiffs filed a sur-reply (Doc. 42). For the reasons explained below, including that Plaintiffs have failed to establish standing to state a claim for declaratory judgment and have also failed to state a claim for quiet title, I recommend that the motion to dismiss be granted.

  1. BACKGROUND

Simply put, this case arises out of a typographical error.2 That is, Plaintiffs Philip and Ingrid Tippett allege that a mortgage document that was recorded by Wells Fargo pertaining

1 Within 14 days after being served with a copy of the recommended disposition, a party may file written objections to the Report and Recommendation’s factual findings and legal conclusions. See Fed. R. Civ. P. 72(b)(3); Fed. R. Crim. P. 59(b)(2); 28 U.S.C. § 636(b)(1)(B). A party’s failure to file written objections waives that party’s right to challenge on appeal any unobjected-to factual finding or legal conclusion the district judge adopts from the Report and Recommendation. See 11th Cir. R. 3-1.

2 It is worth noting that Plaintiffs affirmatively allege that the “discrepancy in the Tippetts’ HELOC mortgage was not a typographical error.” (Doc. 30, ¶ 22). As explained below, however, this allegation is implausible and unsupported, and the parties offer no other explanation for the error.

to their home equity line of credit loan agreement (“HELOC”) had the incorrect date, that Wells Fargo’s attempt to correct it by filing an “Affidavit to Correct a Scrivener’s Error” was done surreptitiously and fraudulently, and that there is now a cloud on the title of their property as a result.

The facts, as alleged in the amended complaint, are as follows. On October 9, 2003, to finance the $125,000 purchase of a home, Plaintiffs Philip and Ingrid Tippett obtained two loans from Wells Fargo: (1) a $100,000 purchase-money loan secured by a first mortgage; and

(2) a $25,000 HELOC loan pursuant to an EquityLine Agreement secured by a HELOC mortgage. (Amended Complaint, Doc. 30, ¶ 19). Depending on the balance at the end of the draw period, the loan balance would either convert to a fully amortizing fixed-rate loan repayable in equal monthly payments for a term of fifteen years (if the unpaid balance was less than $20,000) or thirty years (if the unpaid balance was more than $20,000), with the maturity date being the maturity date of the fixed-rate loan. (Doc. 30, ¶ 20). This is an important aspect of Plaintiffs’ argument, as they contend that the maturity date for the EquityLine Agreement could not be ascertained until the end of the draw period, and only then based on the balance due on the loan. (Doc. 30, ¶¶ 20, 21).

In any event, a HELOC mortgage was prepared and recorded in the public records for Marion County, Florida, that identified October 25, 2013 as the maturity date of the Equity ine Agreement. (Doc 30 ¶ 21, Doc. 30-3, p. 2)). The parties all appear to concede this date was simply an error. Plaintiffs concede that the HELOC mortgage provided that the terms of the EquityLine Agreement controlled over any inconsistent term in the HELOC

mortgage. Under that agreement, depending on the loan balance at the end of the ten year draw period, the maturity date of the EquityLine agreement would have been 2028 (if less than $20,000) or 2043 (if more than $20,000).

This error apparently went unnoticed until 2013. On April 4, 2013, Wells Fargo’s Vice President of Loan Documentation, Joyce Boston, executed and recorded in the public records for Marion County, Florida an “Affidavit of Correction to Correct a Scrivener’s Error,” which states, in part,

“the MATURITY DATE OF THE SECURED DEBT FOR THE SECURITY INTEREST WAS INCORRECTLY TYPED AS 10/25/2013, and that the document was being filed to “correct the MATURITY DATE OF THE SECURED DEBT FOR THE SECURITY INTEREST to show 10/09/2043.”

(Doc. 30-4).

Plaintiffs take issue with the affidavit’s assignment of a 2043 maturity date because, as they contend, the actual maturity date of the agreement would not have been ascertainable for another six months when the 10-year draw period concluded. Plaintiffs allege that, had their account balance fallen below $20,000 by the end of the draw period, the maturity date would have been 2028, not 2043. (Doc. 30, ¶¶ 20, 34). Plaintiffs allege that Wells Fargo did not notify them or secure their permission to unilaterally and materially alter the terms of their HELOC mortgage and that, therefore, they could not have reasonably discovered the Affidavit of Correction.

Plaintiffs also argue that Wells Fargo purported to hold a lien on their property, but that the lien actually expired no later than October 25, 2018.

Plaintiffs reason that, because the Affidavit of Correction was invalid, Wells Fargo did not properly extend its HELOC mortgage lien past October 25, 2013.

Plaintiffs reach this conclusion by reasoning that, under Florida law, the lien terminated within five years of that date, citing Fla. Stat. § 95.281.

Plaintiffs contend that, because the Affidavit of Correction was filed without the terms of the EquityLine Agreement, Wells Fargo has cast a cloud over their title by purporting to extend the lien to October 9, 2043, when under their theory it expired as a matter of law no later than October 25, 2018. Despite this argument, Plaintiffs also concede that “the maturity date for Plaintiffs’ HELOC loan is October 9, 2043.” (Doc. 30, ¶ 33).

Plaintiffs’ amended complaint seeks to certify a class of “All persons who opened a standard HELOC with Wells Fargo, and for whom Wells Fargo recorded an Affidavit of Correction purporting to extend the maturity date of its security interest in the subject property.” (Doc. 30 para. 37). The amended complaint brings two claims:

(1) quiet title; and

(2) declaratory relief under 28 U.S.C. Sec. 2201 & 2202.

LEGAL STANDARDS

“A pleading that states a claim for relief must contain . . . a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). While detailed factual allegations are not required, “[a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570). The court must view the allegations of the complaint in the light most favorable to the plaintiff, consider the allegations of the complaint as true, and accept all reasonable inferences from there. La Grasta v. First Union Sec., Inc., 358 F.3d 840, 845 (11th Cir. 2004). In considering the sufficiency of the complaint, the court limits its “consideration to the well-pleaded factual

allegations, documents central to or referenced in the complaint, and matters judicially noticed.” Id.

A claim is plausible on its face where “the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. Plausibility means “more than a sheer possibility that a defendant has acted unlawfully.” Id. “Where a complaint pleads facts that are ‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of entitlement to relief.’” Id. (quoting Twombly, 550 U.S. at 557) (internal quotation marks omitted). In short, to survive a motion to dismiss a plaintiff must allege something more “than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. (citing Twombly, 550 U.S. at 555).

The Eleventh Circuit uses a two-pronged approach in applying the holding in Ashcroft and Twombly. First, the Court must “eliminate any allegations in the complaint that are merely legal conclusions,” and then, “where there are well-pleaded factual allegations, ‘assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.’” Am. Dental Ass’n v. Cigna Corp., 605 F.3d 1283, 1290 (11th Cir. 2010) (quoting Iqbal, 556 U.S. at 679).

A well-pled complaint may proceed even if it strikes a savvy judge that actual proof of those facts is improbable, and “that a recovery is very remote and unlikely.” Twombly, 550 U.S. at 556. The issue to be decided when considering a motion to dismiss is not whether the claimant will ultimately prevail, but “whether the claimant is entitled to offer evidence to support the claims.” Scheuer v. Rhodes, 416 U.S. 232, 236 (1974), overruled on other grounds by Davis v. Scheuer, 468 U.S. 183 (1984).

Here, Plaintiffs bring suit under the Declaratory Judgment Act, which provides, in pertinent part:

In a case of actual controversy within its jurisdiction … any court of the United States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought. Any such declaration shall have the force and effect of a final judgment or decree and shall be reviewable as such.

28 U.S.C. § 2201(a). “The purpose behind the Declaratory Judgment Act is to afford a new form of relief from uncertainty and insecurity with respect to rights, status, and other legal relations.” Cas. Indem. Exch. v. High Croft Enters., Inc., 714 F. Supp. 1190, 1193 (S.D. Fla. 1989). Specifically, the Act permits actual controversies to be settled before they ripen into violations of law or a breach of contractual duty. Id.

The Declaratory Judgment Act grants to the federal district courts the power to “declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought.” 28 U.S.C. § 2201. An essential element for every declaratory judgment action is the existence of an “actual controversy” between the parties. Aetna Life Ins. Co. of Hartford, Conn. v. Haworth, 300 U.S. 227, 239–40 (1937). An actual controversy exists when “there is a substantial controversy, between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.” Md. Cas. Co. v. Pac. Coal & Oil Co., 312 U.S. 270, 273 (1941). Ordinarily, a controversy is not sufficiently immediate or real where the parties’ dispute is only hypothetical and not yet ripe, has been rendered moot, or where the court’s resolution of the matter would be purely academic. See Texas v. United States, 523 U.S. 296, 300 (1998); Aetna Life Ins. Co., 300

U.S. at 240–41. On the other hand, a court should permit a claim for declaratory judgment to

proceed where declaratory relief would (1) “serve a useful purpose in clarifying and settling the legal relations in issue,” and (2) “terminate and afford relief from the uncertainty, insecurity, and controversy giving rise to the proceeding.” Volvo Constr. Equip. N. Am., Inc. v. CLM Equip. Co., 386 F.3d 581, 594 (4th Cir. 2004).

DISCUSSION

Wells Fargo moves to dismiss the amended complaint on numerous grounds including that Plaintiffs’ claim for declaratory judgment fails for lack of standing and that all of Plaintiffs’ claims fail under Fed. R. Civ. P. 12(b)(6). The Court will address each of Plaintiffs’ claims in turn.

DECLARATORY JUDGMENT

Wells Fargo argues that Plaintiffs lack standing because they have not alleged facts to support any actual harm. Wells Fargo contends that Plaintiffs have simply alleged in a conclusory manner that they have been somehow harmed by the Affidavit of Correction. In fact, Wells Fargo points out that aligning the parties’ intended maturity date with the recorded date benefitted Plaintiffs because Wells Fargo granted Plaintiffs a longer period of time during which to pay on their mortgage without facing foreclosure.

Wells Fargo argues that, at most, Plaintiffs have alleged a procedural violation – not harm. Wells Fargo contends that such “bare procedural violations” are insufficient to establish standing. See Stacy v. Dollar Tree Stores, Inc. 274 F. Supp. 3d 1355, 1364 (S.D. Fla 2017).

In an attempt to allege an injury to establish a basis for declaratory judgment, Plaintiffs allege that they “remain exposed to a lawsuit by Wells Fargo to foreclose the HELOC mortgage should Plaintiffs default on the loan . . . [and] Plaintiffs are not able to sell or

refinance their property free and clear of the Affidavit of Correction.” (Doc. 30, ¶ 35). Wells Fargo contends that Plaintiffs must plead a substantial likelihood of future injury to establish a claim of declaratory relief, and these allegations are insufficient. Wells Fargo points out that Plaintiffs have only pled “contingent future injuries,” such as exposure to a foreclosure suit if they default, or possible difficulty selling the property or refinancing a mortgage. Notably, Plaintiffs have not alleged they are actually in default, that they are selling their property, or that they are refinancing a mortgage. Wells Fargo contends that these omissions are fatal to their request for declaratory judgment. These contingencies may or may not occur and a “’maybe’ chance is not enough.” See, e.g., Carvalho-Knighton v. Univ. of S. Fla. Bd. Of Trs., 2016 WL 7666137, at *5 (M.D. Fla. Mar. 18, 2016) (“[A] ‘perhaps’ or ‘maybe’ chance is not enough.”).

Moreover, Wells Fargo persuasively argues that no harm can be caused by correcting an error to conform to the parties’ actual understanding and agreement. The Court agrees. First, the undersigned finds it difficult to conceive of the harm alleged by Plaintiffs as anything other than speculative. Any theoretical harm alleged is contingent upon a variety of scenarios such as Plaintiffs’ attempting to sell, refinance, or going into default. Second, and most importantly, even as alleged, the harm would be little more than a clarification of the recorded mortgage to reflect the actual understanding and terms between the parties. That said, the Court acknowledges Plaintiffs’ argument that, at the time the Affidavit of Correction was filed correcting the maturity date to 2043 as to their property, there existed the theoretical possibility that Plaintiffs may have paid down their balance and the maturity date would then have been 2028. Plaintiffs do not allege, however, that this possibility ever came to pass. Rather, it appears that when Wells Fargo filed the Affidavit of Correction in the Tippetts’

case, it did so based on the best information available at the time and, perhaps, made an educated guess about what the maturity date would ultimately be. Plaintiffs have not alleged that, ultimately, the 2043 maturity date turned out to be incorrect based on their balance at the end of the draw period.

Plaintiffs allege that the affidavit is invalid due to the circumstances under which it was filed, but they do not allege that it is incorrect in substance. So, the harm alleged by Plaintiffs is contingent at best, and it appears that the contingencies that may have triggered the alleged harm have not occurred.

And, although the affidavit was filed prior to the end of the draw period, it appears that the draw period did close with the Tippetts’ balance in an amount that aligned with a maturity date of 2043 as provided in the terms of the EquityLine Agreement between the parties.

In other words, under the present circumstances, the Affidavit reflects little more than Wells Fargo’s attempt to clarify a typographical error, and to correct the public records to reflect the actual maturity date under the parties underlying agreement.

To be sure, the events might have unfolded differently. As Plaintiffs point out, the Tippetts might have paid down their balance before the end of the draw period. But that was not the case, and those are not the facts alleged in the amended complaint. The court must consider these issues based on the facts alleged, not the universe of possible facts that may have been alleged.

In the motion and response, the parties have cited cases that are only very loosely analogous to the instant case. In light of the circumstances of this case, and the particular facts alleged in the amended complaint, the undersigned concludes that the Plaintiffs have fallen short of the pleading requirements for an actual controversy, which exists when “there is a substantial controversy, between parties having adverse legal interests, of sufficient

immediacy and reality to warrant the issuance of a declaratory judgment.” Md. Cas. Co. v. Pac. Coal & Oil Co., 312 U.S. 270, 273 (1941). Here, the theoretical harm alleged by Plaintiffs is neither substantial nor sufficiently immediate and real to warrant declaratory judgment.

As the Eleventh Circuit has held, in order to have standing to seek declaratory relief, Plaintiffs “must allege and ultimately prove “a real and immediate – as opposed to a merely hypothetical or conjectural – threat of future injury.” Strickland v. Alexander, 772 F.3d 876, 882 (11th Cir. 2014) (Doc. 30, ¶ 33). To this, Plaintiffs state that they “allege that a cloud exists on their title now,” and that the property’s marketability and value has been reduced without their knowledge. (Doc. 30, ¶ 33). These allegations, however, do not pass the plausibility test under the circumstances, as they amount to bare conclusions regarding the impact of the Affidavit of Correction on the Tippets’ property. See Iqbal, 556 U.S. at 678 (pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’”) (quoting Twombly, 550 U.S. at 555). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. (quoting Twombly, 550 U.S. at 570).

Here, there is no sufficient factual matter to support the conclusion about the property’s alleged reduced value and marketability. And, it seems implausible that the affidavit’s correction of a typographical error that has the effect of bringing the recorded mortgage into alignment with the parties’ actual agreement would have any undue negative impact on the value or marketability of the title. Undoubtedly, such errors occur occasionally and common sense dictates that they would be dealt with as a matter of course by prospective real estate brokers, buyers, mortgage lenders or refinancers, or title insurance representatives. Any impact appears to be hypothetical, as opposed to real and immediate harm. For these

reasons, the undersigned submits that Plaintiffs have failed to establish a real and immediate injury and have therefore failed to establish standing. Consequently, Plaintiffs’ claim for declaratory relief should be dismissed for lack of justiciability.

QUIET TITLE

First, the undersigned observes that Plaintiffs’ quiet title claim fails for lack of standing for the same reasons discussed above. Wells Fargo has also moved to dismiss the amended complaint on the grounds that Plaintiffs’ claims fail under Federal Rule of Civil Procedure 12(b)(6). Wells Fargo also argues that the quiet title claim fails because Plaintiffs have failed to allege all necessary elements.

Under Florida law, in order to state a claim for quiet title, a plaintiff must establish (1) the plaintiff’s valid title; (2) the manner which the plaintiff obtained the title; (3) the basis upon which the defendant asserts an interest on the title; and (4) the invalidity of the defendant’s interest in the property. Barrows v. Bank of Am., NA, 2014 WL 7337429, at *2 (M.D. Fla. Dec. 23, 2014). “A claim for quiet title in Florida ‘must not only show title in the plaintiff to the lands in controversy, but also that a cloud exists, before relief can be given against it.’” Lane v. Guar. Bank, 552 F. App’x 934, 936 (11th Cir.2014) (quoting Stark v. Frayer, 67 So. 2d 237, 239 (Fla. 1953)).

Here, Wells Fargo contends that Plaintiffs cannot show that the defendant’s interest is invalid. Wells Fargo argues, “on the contrary, it is precisely what Plaintiffs agreed to when they executed the agreement for their HELOC in 2003.” (Doc. 32, p. 14). The Court finds this argument persuasive. Plaintiffs certainly dispute the procedure and unilateral nature by which the affidavit was filed in the public records, but they do not dispute its substance. That said, Plaintiffs do affirmatively argue that “[a]ny interest Wells Fargo had in the Tippetts’

property terminated no later than October 25, 2018,” citing ¶ 33 of the amended complaint. (Doc. 30). That paragraph, however, merely recites Plaintiffs’ convoluted and conclusory argument that, under Florida Statutes § 95.281, the lien terminated in 2018. (Doc. 30, ¶ 33). In other words, Plaintiffs’ contention that Wells Fargo’s interest in the property terminated in 2018 is a mere legal conclusion, as opposed to a well-pled factual allegation, and must be eliminated. See Am. Dental Ass’n v. Cigna Corp., 605 F.3d 1283, 1290 (11th Cir. 2010).

Plaintiffs do not go so far as to allege that the bank’s interest is invalid. Rather, Plaintiffs stand on their argument that Wells Fargo’s interest terminated in 2018. They largely dispute the procedure and timing of the affidavit and, based on their interpretation of the Florida Statutes regarding mortgage liens, offer the convoluted theory that Wells Fargo unlawfully and “surreptitiously” extended its interest beyond what it originally appeared to be based on the initial incorrect maturity date of 2013. Plaintiffs also allege that Wells Fargo exceeded its authority by unilaterally filing the affidavit without obtaining Plaintiffs’ permission. Yet, all of that is beside the point because Plaintiffs ultimately do not dispute that Wells Fargo has a valid interest and that the Affidavit of Correction was intended to bring the recorded documents into alignment with the parties’ intentions and agreement. See Byrd v. Bank Mortgage Solutions, LLC, 2014 WL 12861313 (S.D. Fla. Apr. 17, 2014), R &R adopted, 2014 12861416 (S.D. Fla. Sept. 8, 2014) (dismissing a quiet title claim and reasoning that the plaintiff did not dispute his agreement or his obligations, but cited a range of legal defects, and finding that the subject mortgage and note did not create an improper or unlawful cloud on this title).

It is worth noting that Plaintiffs admit they “still have a contractual obligation to pay the balance of the loan, even if that debt is not secured by Wells Fargo’s HELOC mortgage.”

(Doc. 37, p. 16). Plaintiffs’ position is perplexing. Despite conceding that they are contractually obligated to pay the loan balance, and that the terms of the “HELOC mortgage provided that the terms of the EquityLine Agreement controlled over any inconsistent term in the HELOC mortgage,” Plaintiffs nonetheless contend that Wells Fargo’s interest in the Tippetts’ property terminated in 2018. (Doc. 37, p. 4, 7, Doc. 30-3, p.7). Plaintiffs’ argument is illogical. Even if the lien recorded in the public records terminated as a matter of fact or procedure, Wells Fargo’s true interest, i.e., the right to a lien against the property was not extinguished because it was established under the EquityLine Agreement. (Doc. 30-2). Notably, Plaintiffs have not cited a single case suggesting that a bank’s filing an Affidavit of Correction or similar document under circumstances such as occurred here is sufficient to establish a claim for quiet title. Indeed, relative to the sufficiency of their quiet title claim, the only case cited by Plaintiffs is Byrd, 2014 WL 12861313, which was cited by Wells Fargo, and which Plaintiffs only cite in an attempt to distinguish it. Simply put, Plaintiffs offer no authority for their proposition that the circumstances of this case are sufficient to support a claim for quiet title.

Meanwhile, an informal survey of Florida law provides examples of cases where a quiet title action was the appropriate vehicle to redress the parties’ dispute. See, e.g.,Bd. of Trustees of Internal Imp. Tr. Fund v. Fla. Pub. Utilities Co., 599 So. 2d 1356, 1357 (Fla. 1st DCA 1992) (quiet title action to determine dispute over ownership of body of water); Brown v. Semple, 204 So. 2d 229, 230 (Fla. 3d DCA 1967) (quiet title action to determine lot boundaries); Jones v. Muldrow, 921 So. 2d 762, 763 (Fla. 1st DCA 2006) (quiet title action to resolve dispute regarding claim based on the theory of boundary by acquiescence). Suffice it to say, neither Plaintiffs nor the Court has identified any precedent that suggests that, in

circumstances such as presented by the alleged facts in this case, a claim for quiet title is supported.

In reaching the conclusion that Plaintiffs have failed to state claims for quiet title and declaratory judgment, it is not necessary for the Court to decide the multitude of other issues Plaintiffs raise in their amended complaint and pleadings. Those issues include whether the affidavit is an “invalid lien,” whether Plaintiffs’ interpretation of when Wells Fargo’s lien terminated is correct, and whether Wells Fargo violated its authority or the terms of the parties’ contract by unilaterally filing the Affidavit of Correction. Resolution of those issues is not necessary to the Court’s determination that Plaintiffs have failed to state claims for quiet title and declaratory relief.

For the reasons explained above, the Court submits that Plaintiffs’ claims also fail under Rule 12(b)(6). Consequently, the Court need not address Wells Fargo’s additional argument that both of Plaintiffs’ claims are time barred.

As a penultimate matter, the Court notes that Plaintiffs attempt to connect the Affidavit of Correction in this case with “numerous other well-publicized instances” where they contend the bank “has privileged profits over the contracts it has with its customers.” In considering the sufficiency of Plaintiffs’ claims, however, the Court must consider the allegations in the amended complaint, as opposed to the unspecified wrongs to which Plaintiffs allude.

Finally, the undersigned acknowledges that Plaintiffs requested a hearing on the motion to dismiss. The undersigned, however, has determined that a hearing was not necessary in making these recommendations.

RECOMMENDATION

For the reasons stated above, I recommend that Wells Fargo Bank, N.A.’s motion to dismiss the amended class action complaint (Doc. 32) be Granted. Plaintiff’s motion for a hearing on the motion to dismiss (Doc. 38) is Denied.

Recommended in Ocala, Florida on June 4, 2021.

PHILIP R. LAMMENS
United States Magistrate Judge

Copies furnished to:

Presiding District Judge
Counsel of Record
Unrepresented Party
Courtroom Deputy

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Eleventh Circuit

Southern Florida Judge Orders Retrial for Fraud by Prosecutors. It Wasn’t Lyin’ Judge Marra

Judge Darrin P. Gayles claims during a court hearing the original prosecutors “deliberately misled this court.” He orders a new AUSA team.

Published

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July 16, 2021: S.D. Fl. Judge Orders New Trial After AUSAs ‘Deliberately Misled’ Him

A Florida federal judge said Friday he would be ordering a new trial — with a new prosecution team — for a trio of men found guilty of swiping millions of dollars from elderly people in a sweepstakes scheme, saying during a hearing that the original prosecutors “deliberately misled this court.”

A federal judge in Miami has ordered a new trial for three men found guilty in a fraudulent sweepstakes scheme after concluding that federal prosecutors had “knowingly invaded the defense camp” while lying to the court about it.

U.S. District Judge Darrin Gayles of the Southern District of Florida said two initial prosecutors in the case “deliberately misled this court.”

Law360 and the Miami Herald have coverage of Gayles’ remarks, made during a hearing Friday.

Gayles said he had allowed the three Florida men to be tried without knowing the extent of prosecutors’ alleged wrongdoing, according to the coverage.

Prosecutors had received handwritten notes from a fourth defendant who attended defense meetings without disclosing that he had obtained a plea deal with prosecutors, Gayles said during the hearing. The other defendants were working together under a joint defense agreement.

The fourth defendant, 53-year-old John Leon of Wilton Manors, Florida, had received government authorization to attend strategy meetings. Yet prosecutors lied about whether Leon had attended more than one meeting and whether they approved his participation, Gayles said.

One of the federal prosecutors had countered in a court filing that Leon’s cooperation was “kept covert” because he was cooperating with the government against a noncharged defendant, according to the Miami Herald. The prosecutor also said Leon had been instructed not to share privileged information.

The Florida defendants—46-year-old Matthew Pisoni of Fort Lauderdale, Florida; 42-year-old Marcus Pradel of Boca Raton, Florida; and 39-year-old Victor Ramirez of Aventura, Florida—had been convicted of conspiracy to commit mail fraud in 2017. They were accused of telling their scam victims that they had won a sweepstakes prize, and they had to pay $20 to $50 to redeem it.

The defendants sought a new trial after receiving new evidence obtained during an investigation by the U.S. attorney’s office and the Department of Justice’s Office of Professional Responsibility.

The government countered that much of the “newly discovered” evidence cited by the defendants wasn’t material and had no exculpatory value.

Department of Justice
U.S. Attorney’s Office
Southern District of Florida

FOR IMMEDIATE RELEASE

Four South Florida Residents Sentenced to Prison for Conspiring to Commit Sweepstakes Mail Fraud

Wednesday, November 29, 2017 | REPUBLISHED BY LIT: JUL 19, 2021

Four Florida residents were sentenced to prison terms ranging from 42 months imprisonment to 84 months imprisonment for participating in a sweepstakes mail fraud scheme.

Benjamin G. Greenberg, Acting United States Attorney for the Southern District of Florida, Kelly R. Jackson, Special Agent in Charge, Internal Revenue Service, Criminal Investigation (IRS-CI), and Antonio J. Gomez, Inspector in Charge, U.S. Postal Inspection Service (USPIS), Miami Division, made the announcement.

Matthew Pisoni, 44, of Fort Lauderdale, Marcus Pradel, 41, of Boca Raton, and Victor Ramirez, 38, of Aventura, were found guilty of conspiring to commit mail fraud, in violation of Title 18, United States Code, Section 1349, after a five-week trial that ended on July 26, 2017. John Leon, 50, of Fort Lauderdale, previously pled guilty to conspiring to commit mail fraud, in violation of Title 18, United States Code, Section 371.

Today, United States District Court Judge Gayles sentenced Pisoni and Ramirez to 84 months imprisonment; Pradel to 78 months imprisonment; and Leon to 42 months imprisonment.

The trial evidence established that the four defendants, Pisoni, Pradel, Ramirez and Leon, falsely notified individuals by mail that they had won a substantial prize. The letters the defendants sent fraudulently represented that the recipients needed to pay a fee ranging from $20 to $50 to the defendants in order to redeem their purported winnings. During the course of the mail fraud conspiracy, more than 100,000 victims in the United States and abroad were fraudulently induced to pay the fees by the defendants’ misleading claims that they had won a prize. The fraudulent letters directed victims to pay the fees in cash or by check or money order payable to fictitious companies. The defendants then either processed the victims’ payments through independent payment processors or deposited them into shell bank accounts controlled directly and indirectly by the defendants and their co-conspirators. In total, over $25 million in victim payments went into the defendants’ and co-conspirators’ bank accounts.

Mr. Greenberg commended the investigative efforts of the IRS-CI, USPIS, Federal Trade Commission, Aventura Police Department, and other local and international law enforcement agencies. The case is being prosecuted by Assistant U.S. Attorneys Elijah Levitt, and H. Ron Davidson.

Related court documents and information may be found on the website of the District Court for the Southern District of Florida at www.flsd.uscourts.gov or on http://pacer.flsd.uscourts.gov.

‘Breathtaking’ revelation delays start of prison term for men in $25M sweepstakes fraud

JAN 12, 2018 | REPUBLISHED BY LIT: JUL 19, 2021

Three South Florida men convicted of operating a $25 million sweepstakes fraud were supposed to turn themselves in to start serving their punishments on Friday afternoon.

But a judge has agreed to delay their prison surrenders after what the defense calls outrageous last-minute revelations from federal prosecutors.

It’s the latest twist in a controversial case in which victims, mostly seniors, were tricked into sending money to claim a fictitious cash prize.

“The government has disclosed breathtaking new evidence … demonstrating that its witnesses testified falsely … and that the prosecutors made misleading arguments to the court,”

appeals attorney David Oscar Markus wrote in a court filing.

Matthew Pisoni, 45, of Fort Lauderdale, Marcus Pradel, 41, of Boca Raton, and Victor Ramirez, 38, of Aventura, were found guilty of mail fraud conspiracy after a jury trial last year. John Leon, 50, of Wilton Manors, pleaded guilty to the same charge in 2016 and cooperated with investigators.

Leon was going to testify against the other three men but U.S. District Judge Darrin Gayles barred him from doing so in late 2016.

At the time, the judge also blasted the U.S. Attorney’s Office for allowing Leon to spy on his co-defendants — and their attorneys — after Leon had secretly made a plea deal with the prosecution.

The judge called the prosecution’s handling of the case “extraordinary.”

Judge blasts federal prosecutors over secret deal that led to spying on defense

“I don’t know what’s happening at the U.S. Attorney’s Office. This is the latest of a series of incidents that is affecting the credibility of this office,”

the judge said during the 2016 hearing.

“Someone has got to look at this thing … There’s a problem here that needs to be rectified in some way.”

Defense attorneys for the three men said they were blindsided by prosecutors and Leon’s defense attorney, Omar Johansson.

The problem was different from regular snitching by informants, they said, because all four men had pleaded not guilty in 2015 and, at the time, they and their attorneys had a formal agreement to work together and come up with defense strategies.

Anyone who wanted out was supposed to give 48 hours’ notice to the others.

The judge rejected their request to throw out the charges before trial because of what the defense called an illegal “invasion of the defense camp” by the prosecution.

During the 2016 hearing, prosecutors H. Ron Davidson and Elijah Levitt told the judge they had thought it was essential to keep Leon’s cooperation secret because he was working undercover for them on another related investigation.

They said they later regretted not running their decision up the chain of command at the U.S. Attorney’s Office in Miami.

The judge said that, at a minimum, they should have told their bosses and asked for the judge’s explicit approval.

The prosecutors also told the judge at the hearing they had never received any documents from Leon.

The three men went to trial and were convicted, without Leon’s testimony.

Pisoni and Ramirez were sentenced to seven years in federal prison, Pradel to 6 ½ years and Leon to 3 ½ years. Leon is still expected to begin serving his sentence on Tuesday.

Judge Gayles agreed Thursday to let the other three men remain free until at least March 16. Their attorneys have requested a court hearing to find out more about the newly released information.

They may seek a new trial or use it on appeal.

Earlier this week — three days before the men were due to go to prison — prosecutors filed a court document saying they wanted to “correct” the record. They revealed that Leon gave prosecutor Levitt a document that they now believe may have been a chart or timeline — compiled for the defense by Pradel — which they had claimed they never received.

They now can’t find the document, they wrote.

“The government believes that this document may have been the timeline discussed during the hearings, but the government cannot be certain because the document was placed in a sealed file folder without being examined and no federal agent or Assistant United States Attorney has ever opened the sealed file folder and read the document contained therein,”

they wrote.

“Moreover, Assistant United States Attorney Levitt has exhaustively searched his office’s records but has been unable to locate the sealed file folder with the document.”

Prosecutors, who previously said in court they had rejected Leon’s offer of the chart, also revealed that Leon gave handwritten notes to an IRS agent.

Pisoni, the son-in-law of the late self-help guru Wayne Dyer, was the ringleader of the fraud, according to prosecutors.

Markus, the attorney handling Pisoni’s appeal, declined to comment on the legal aspects of the case.

Pisoni returned home when he learned of the two-month reprieve on Thursday after he had already taken a flight to New Orleans on his way to surrender at his designated prison, Markus said.

The new filing raises more questions than it answers and calls “into question the credibility of the government’s presentation, witnesses, and evidence,” Markus wrote.

A spokeswoman for the U.S. Attorney’s Office declined to comment on the pending case, citing Department of Justice policy.

The U.S. Attorney’s Office has had similar issues in the past, Judge Gayles noted in the 2016 hearing.

He mentioned a reprimand issued in 2009 by a judge who ordered prosecutors to pay a defendant more than $600,000.

That judge ruled prosecutors and a Drug Enforcement Administration agent acted “vexatiously and in bad faith” when they secretly recorded a Miami defense lawyer, Markus, and his investigator in a questionable witness-tampering investigation.

An appeals court later ruled Dr. Ali Shaygan, who was found not guilty of prescription drug charges, was not entitled to the money because of how Judge Alan Gold handled the reprimands of the prosecutors.

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Eleventh Circuit

Florida Bar: Y’all Are In Contempt for Not Answering Complaints

The Florida Bar do not suspend the unresponsive lawyers, they give them a public slap. Forget about the Complainants – it’s Vacation time.

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Summer Vacation Already Started at the Fl. Bar, a Very Quiet Month of Discipline

JUN 24, 2021 | REPUBLISHED BY LIT: JUL 2, 2021

The Florida Supreme Court in recent court orders disciplined five attorneys, disbarring one, suspending one, revoking the licenses of one, and reprimanding two.

Ben Ira Farbstein, 4018 Sheridan St., Hollywood, public reprimand effective immediately following an April 12 court order.

(Admitted to practice: 1982)

Farbstein was held in contempt for failing to timely respond to inquiries of the Bar.

(Case No. SC21-92)

Colleen E. Huott, 2385 NW Executive Center Drive, Suite 100, Boca Raton, disbarred, effective immediately following a May 20 court order.

(Admitted to practice: 2005)

Huott failed to respond to 10 grievances, two Orders to Show Cause from the Florida Supreme Court and a subpoena duces tecum.

Additionally, Huott received 10 trust account overdraft notices, which the Bar could not investigate due to Huott ignoring all inquiries by the Bar.

(Case No: SC21-383)

Erica Helene Kobloth, 5613 Pacific Blvd., Apt. 3307, Boca Raton, suspended for three years effective immediately following a May 19 court order.

(Admitted to practice: 2012)

Kobloth was held in contempt of the Court’s order dated Nov. 2, 2020, for failing to comply with Rule 3-5.1(h) requirements of notifying clients, opposing counsel and tribunals of her suspension.

(Case No: SC21-432)

Beverly T. Shaw, 6865 19th St. South, St. Petersburg, public reprimand effective immediately following a May 19 court order.

(Admitted to practice: 1998)

Shaw was held in contempt and publicly reprimanded for failing to timely respond to official Bar inquiries.

(Case No: SC21-157)

Heyward Silcox III, 22 Tulip Lane, Apt. 307, Cocoa Beach, disciplinary revocation with leave to seek readmission after five years, effective 30 days following a May 6 court order.

(Admitted to practice: 2018)

On or about June 26, 2020, in the United States District Court, Northern District of California, Silcox pleaded guilty to three counts of illegal importation of a controlled substance, specifically the Schedule IV narcotic Tramadol.

Prior to his plea, Silcox successfully completed a chemical dependency treatment program on March 6, 2020.

Silcox has also signed a two-year contract with Florida Lawyers Assistance, Inc.

(Case No: SC21-290)

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Editors Choice

The Senate Judiciary Committee Has a Responsibility to Forcefully Reject this Judicial Overreach

LIF and LIT has proven beyond a reasonable doubt that there are many rogue judges on our Federal Benches. This request is in direct violation of the US Constitution.

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Principles for Federal Judicial Privacy Legislation
Protection of Judges’ Personally Identifiable Information

Further to our article on Judges wanting God Status and Protection from Scrutiny by Tax Payers and Citizens, the following article transcribes the letter circulating congress and the Judicial Senate Committee…

September 4, 2020
Honorable Lindsey Graham Chairman
Committee on the Judiciary United States Senate Washington, DC 20510

Dear Mr. Chairman:

In my August 19, 2020 letter to House and Senate leadership, I outlined six recommendations approved by the Judicial Conference of the United States to improve judicial security.

That letter was prompted by the July 2020 attack on the family of United States District Court Judge Esther Salas that resulted in the murder of her 20-year-old son, Daniel, and the critical wounding of her husband, Mark.

Unfortunately, too many others in our judicial family have experienced similar tragedy and grief. The murders of United States District Judge John Wood (1979), United States District Judge Richard Daronco (1988), United States Circuit Judge Robert Vance (1989), United States District Judge John Roll (2011), family members of United States District Judge Joan Lefkow (2005), and now the son of United States District Judge Esther Salas were tragic targeted attacks against federal judges and their families.

Unfortunately, threats have greatly multiplied over the past five years and require immediate legislative action to enhance security protections.

Among the recommendations approved by the Judicial Conference is to seek legislation to enhance the protection of judges’ personally identifiable information (PII), particularly on the internet.

Another recommendation is to seek legislation to eliminate the sunset provision in 5 U.S.C. app. § 105(b)(3)(E), which grants the Judicial Conference authority to redact financial disclosure reports.

Other recommendations are for additional appropriations – for the upgrade, installation, and continued sustainment of the Home Intrusion Detection Systems program; for additional deputy U.S. Marshals; and for the Federal Protective Service (FPS) to fund the required upgrades for courthouse security camera systems.

A final recommendation is to support the development of a resource to monitor the public availability of judges’ PII, inform judges of security vulnerabilities created by this information, and where necessary, advise the appropriate law enforcement of an inappropriate communication.

James C. Duff
Secretary

Enclosures

cc:
Honorable Dianne Feinstein
Honorable Cory Booker
Honorable Bob Menendez

The judiciary supports the protection of and prevention of unauthorized release of personally identifiable information of federal judicial officers and their immediate families (“Judges’ Personally Identifiable Information” or “JPII”), particularly such information that is available and distributed through the internet. “Immediate family” includes a judicial officer’s spouse, child, parent, or any blood relative of the judicial officer or the judicial officer’s spouse who lives in the same residence as the judicial officer.

The goal of this legislation is to ensure that federal judicial officers are able to administer justice fairly without fear of personal reprisal from individuals affected by decisions made in the course of carrying out their professional duties. The purposes of the legislation are to remove and/or limit access to JPII from publicly displayed records, as well as to prohibit any person, business, association, or agency from posting, displaying, selling, sharing, transferring, or trading JPII with others. Federal privacy legislation shall not be construed to impair free access to decisions and opinions expressed by judicial officers in the course of carrying out their public duties.
The judiciary recommends enactment of federal legislation that incorporates the following:

1. PROTECTION OF FEDERAL JUDICIAL OFFICERS including the Chief Justice of the United States; the Associate Justices of the Supreme Court of the United States; judges of the United States courts of appeals; district judges and magistrate judges of the United States district courts, including the district courts in Guam, the Northern Mariana Islands, and the Virgin Islands; judges of the Court of Appeals for the Federal Circuit, Court of International Trade, United States Bankruptcy courts, United States Court of Federal Claims, and any court created by Act of Congress, the judges of which are entitled to hold office during good behavior. The legislation shall extend to any individual identified above, whether in active, senior, recalled, or retired status, as well as any individual whose nomination to a position listed above has been transmitted by the President of the United States to the United States Senate and whose nomination remains pending before the United States Senate.

2. PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION of judicial officers and their immediate family members, to include but not be limited to the primary home address; date of birth; social security number; driver’s license number; voter registration information that includes a home address; bank account and credit or debit card information; property tax records and any property ownership records, including a secondary residence and any investment property; birth and marriage records; marital status; personal email addresses; home or mobile phone number; vehicle registration information; family member’s employer, daycare, or school; personal photographs or photographs of a judicial officer’s home; religious, organization, club, or association memberships; identification of children under the age of 18; and any other unique biometric data or piece of information that can be used to identify an individual.

3. PROHIBITION OF PUBLIC DISTRIBUTION OF JPII BY ANY FEDERAL GOVERNMENT AGENCY. Federal government agencies shall have an affirmative duty to prevent the public disclosure of JPII, and upon written request shall remove restricted JPII from internet sites or publicly accessible federal government databases within 48-72 hours of the request.

4. MANDATORY REMOVAL OR REDACTION OF JPII UPON WRITTEN REQUEST SERVED ON ANY PERSON, BUSINESS, ASSOCIATION, OR AGENCY. Upon written request, a person, business, association or agency must, within 48-72 hours of receipt of the request, redact from the public record any existing JPII and may not thereafter knowingly post, display, sell, share, trade or transfer JPII, including publicly accessible and displayed content. No person, business or association shall solicit JPII with intent to do harm to a judicial officer or immediate family member. The written request by a judicial officer, or his or her representative, to remove and/or to redact from the public record JPII of the judicial officer or an immediate family member shall not require a showing of fear of harm or immediate threat and shall remain effective until revocation of the request by the judicial officer or a surviving immediate family member.

5. ENFORCEMENT/REMEDIES shall include a private right of action (including injunctive or declaratory relief), civil enforcement authority by an appropriate federal department or regulatory agency, and limited criminal enforcement authority.

6. PREEMPTION OF STATE LAWS. Federal legislation must mandate and/or provide incentives for the protection of JPII held at the state/county/local level – at a minimum including motor vehicle registration and driver’s license information; real estate transaction and property tax records; and voter registration information that includes a home address. Restricted JPII of federal judicial officers and immediate family members must be exempt from state public information laws. Federal legislation might include grant programs to assist states in complying with these provisions.

Permanent Authority to Redact Sensitive Security Information from Judicial Financial Disclosure Reports

PROPOSED LEGISLATION:

SECTION 1. REDACTION AUTHORITY CONCERNING SENSITIVE SECURITY INFORMATION.

Section 105(b)(3) of the Ethics in Government Act of 1978 (5 U.S.C. App.) is amended by striking subparagraph (E).

BACKGROUND AND JUSTIFICATION:

• The Judicial Conference of the United States seeks legislation to eliminate the sunset provision in 5 U.S.C. app. § 105(b)(3)(E), which grants the Judicial Conference authority to redact financial disclosure reports.

• The need to provide permanent redaction authority is a sensitive security matter. A lapse in redaction authority, which has occurred in the past, creates significant security risks to judges and judiciary employees. Federal judges and judiciary employees, like probation officers, routinely interact with disgruntled litigants and convicted criminals who may bear grudges against them. Without redaction authority, these individuals will be able to learn sensitive information such as the unsecured locations of judges, employees, and their families. Redaction of this sensitive information protects these public servants and their families from harm.

• Judges and certain judicial employees are required to file financial disclosure reports under the Ethics in Government Act of 1978, as amended. Congress has recognized judges and judicial employees have been the subject of assault, threats and harassment. Accordingly, Congress enacted legislation that grants the Judiciary the authority to redact certain statutorily required information in a financial disclosure report in limited instances when the release of the information could endanger a judicial officer or employee or his or her family (The Identity Theft and Assumption Deterrence Act of 1998, Section 7, P.L. 105-318, October 30, 1998.) We thank the Congress for their past support of this critical safeguard.

• Congress has extended the authority to redact six times since 1998. In 2012, Congress passed an extension of the sunset provision through December 31, 2017. Unfortunately, the redaction authority expired on January 1, 2018 because Congress did not take final action on eliminating the sunset provision or renewing the authority. It wasn’t until March 23, 2018, upon enactment of the Consolidated Appropriations Act of 2018 that redaction authority was again extended to December 31, 2027.

• Congress previously has indicated support for legislation to make this authority permanent. As noted in House Report 115-332, the House has consistently supported permanent reauthorization of redaction authority. The House passed permanent redaction authority in 2011 by a vote of 384-0. In October 2017, the Senate Committee on Homeland Security and Governmental Affairs favorably reported to the Senate S. 1584 which provided for permanent redaction authority (see Senate Report 115-172.)

• The Judicial Conference uses its redaction authority carefully and reasonably. Each year a very small percentage of the financial disclosure reports filed contain an approved redaction of some information in the report. In 2019, 4,379 individuals employed in the judicial branch were required to file a financial report and 155 filers, or just 3.5 per cent, requested redaction. Of those, 150 requests were granted in full or in part. Of the 34,612 reports released to the public, only 1,970 contained partial redactions. Although only a small percentage of reports released to the public are approved for any redactions, the written application to examine a financial disclosure report and the ability to withhold sensitive information remain important protections for the judicial officers and employees who are most at risk for facing serious threats and inappropriate communications.

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