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Tanya Jones v. Diane Rosenberg , No. 124, September Term, 2007
REAL EST ATE – FOR ECLOSU RES –
The availability of discovery related to exceptions to a foreclosure sale rests in the sound
discretion of the court.
IN THE COURT OF SPECIAL APPEALS
September Term, 2007
Eyler, Jam es R.,
Murphy, Jr., Joseph F.
(Associate Judge of the Court of
Appeals, specially assigned),
Opinion by Eyler, James R., J.
Filed: January 31, 2008
This case raises several issues stemming from a real estate foreclosure action
initiated in the Circuit Court for Ch arles County by substitute trustees Diane S . Rosenberg
and Mark Meyer, appellees, against mortgagors Donna P. Jones and Tanya L. Jones,
appella nts. Ap pellants unsuc cessfu lly sough t to stay for eclosu re prior to the sale.
Following the foreclosure sale, appellants filed exceptions to the sale and sought
discovery. The circuit court denied discovery, overruled appellants’ exceptions, and
ratified t he fore closure sale.
On app eal, appellan ts raise severa l issues: (1) w hether the c ircuit court erre d in
denying appellants’ requests for injunctive relief to stop the foreclosure sale, under
Maryland Rule 14-209(b); (2) whether the circuit court erred in quashing appellants’
notices of deposition and subpoenas duces tecum served on appellees shortly before the
hearing on appellants’ second request for injunctive relief;1 (3) whether the circuit court
erred in ratifying the foreclosure sale; (4) whether the circuit court erred in denying
appellants’ motion to stay enforcement of the judgment ratifying the sale, pending appeal
to this Court; and (5) whether the circuit court erred in denying appellants’ motion to alter
or amend the judgment ratifying the sale.
Perceiv ing no e rror, we shall af firm.
The second request for injunctive relief also served as exceptions to the
foreclo sure sale .
On August 31, 2005, appellants executed a deed of trust for property located at
10693 Jacksonhole Place in Charles County, Maryland, to secure a loan in the amount of
$224,8 00. Th e lende r was G reenPo int Mo rtgage F unding , Inc. of S anta R osa, Ca lifornia .
The deed of trust included a provision that the borrower, after default, had a right to have
enforcement of the deed of trust suspended upon compliance with certain conditions,
including the payment of all amounts due, plus expenses. The deed also contained an
adjustable rate rider, with an initial interest rate of 1 percent. The deed provided the
interest rate would change on November 1, 2005, by a rate calculated by adding 3.375
percent to th e current rate index, but n ot exceed ing 12 per cent. The in itial monthly
payment was $723.05. The monthly payments were subject to change each year, and
were to increase substantially after November 1, 2005.
As time progressed, the interest rate on the loan increased, and the amount of the
periodic pa yments ow ed by appellan ts increased. B y October, 20 06, the loan was in
default, triggering acceleration of the loan balance. Appellants were notified that the
matter would proceed to foreclosure. Upon receiving notice, appellants, in a letter dated
October 30, 200 6, requested validation of the d ebt. On Octobe r 30, 2006, the foreclosu re
action was docketed in circuit court, and appellees were appointed as substitute trustees
that same day. Appellees’ statement of debt showed a balance due in the amount of
$238,568.16, which consisted of $225,273.78 principal, accrued interest and other
charge s in the a moun t of $12 ,780.18 , comp uted at a n interes t rate of 6 .875 pe rcent.
Appellees filed a petition for a nominal bond on October 30, 2006, which was approved
on Novem ber 20, 2006. The bond was filed o n Novem ber 29, 2006, and the foreclosure
sale wa s sched uled fo r Novembe r 29, 20 06.
On November 10, 2006, appellees sent a letter to appellants, by certified mail and
first class mail, notifying them that the foreclosure action had been filed and that an
auction sale of the property would occur on November 29, 2006. On November 20, 2006,
appella nts, pro se, filed in circuit court a motion for an emergency injunction to stop the
foreclo sure sale and to q uash se rvice. T he mo tion did not con tain a su pportin g affid avit.
On December 8, 2006, appellees responded to the motion.
The circu it court did no t rule on app ellants’ motio n for an em ergency injun ction to
stop the for eclosure sa le and to qu ash service prior to the fo reclosure sa le, and the sa le
occurred o n Nove mber 29 , 2006. On Decem ber 6, 2006 , the report of sale and af fidavit
of notice were filed. The property was sold to Craig Heurich and Alison Mason for
$262,000, which was in excess of the amount owed by appellants, according to the
statement of debt. The circuit court issued a notice that the sale would be ratified on
Januar y 5, 2007 .
On D ecemb er 21, 20 06, app ellants, pro se, filed a second motion for an emergency
injunction to stop the foreclosure sale or, in the alternative, to stop the ratification of the
sale. The objections stated in the motion included lack of an opportunity to cure the
default; lack of notice of the foreclosure sale by registered mail; that appellants had filed
suit against appellees in the United States District Court for the District of Maryland on
November 17, 2006, alleging that the deed of trust violated federal mortgage laws;2 that
appellants submitted a surety bond on Novem ber 20, 2006, to the clerk o f the circuit court
and the bond covered any debt owed;3 that appellants were denied due process; and
certain other objections re lating to the fo rm of the f oreclosure docume nts. Appe llants
also alle ged tha t they paid the deb t throug h an “in ternatio nal bill o f exch ange,” 4 although
appellants n ow con cede such docume nts are not rec ognized b y Maryland co urts as valid
On December 27, 2006, appellees responded to appellants’ motion, asserting that
appellants’ request for an injunction did not comply with the affidavit requirements of
Maryland Rule 14-209(b); the international bill of exchange was a fraudulent document
and frivolous; the purported bond filed by appellants was not a proper bond; the stated
grounds of appellants’ motion were without merit and did not state a basis for granting an
Appellants’ complaint in the United States District Court was dismissed on
February 5, 2007. Appellants appealed the dismissal of the complaint and the United
States Court of Appeals for the Fourth Circuit affirmed the dismissal on October 24,
2007. A copy of the complaint is attached to this opinion as Appendix A. Through other
cases pending on this Court’s docket, we a re aware that other deb tors in foreclosure
procee dings h ave file d simila r comp laints in f ederal c ourt.
The doc ument is fa cially invalid. A c opy is attached to this opinion as Appe ndix
The doc ument is fa cially invalid. A c opy is attached to this opinion as Appe ndix
injunction; to th e extent the c ourt view ed appellan ts’ motion as constituting e xceptions to
the foreclo sure sale, all of the excep tions had to b e overruled ; upon def ault, appellan ts
had no right to cure, only a right to redem ption; on Novem ber 10, 2006, appe llants were
mailed a rein state quote a nd payoff q uote, and a ppellants ha d an opp ortunity to reinstate
their loan but failed to do so; appellees were in full compliance with notice requirements;
and appellants had not set forth any procedural irregularities with particularity. Appellees
requested that the court deny appellants’ request for an emergency injunction to stop
foreclosure, deny appellants’ exceptions to the foreclosure sale, and grant further relief as
the court deemed appropriate.
The court scheduled a hearing on appellants’ motion for an injunction against
foreclosure and exceptions to the sale and appellees’ response, to be held on February 27,
2006. On February 12, 2006, counsel entered an appearance on behalf of appellants. 5
On February 21, 2007, appellants moved for a continuance of the hearing, which was
denied on February 23, 2007. On February 26, 2007, appellants moved for a statement of
payout and arrearage owed. Prior to the hearing, appellants served notices of deposition
and subpoenas duces tecum on appellees, to occur on March 6, 2007. On February 27,
2007, the same day as the motions hearing, appellees moved to quash the notices of
deposition and subpoenas duces tecum.
At the hearing,on February 27, 2006, appellants requested discovery of the original
Appellan ts continue to be represe nted on ap peal, but by diff erent coun sel.
loan documents, including the original deed of trust, in order to determine whether the
mortgage was usurious and improper, as well as discovery of whether appellants received
actual notice of the foreclosu re sale. By order entered on M arch 2, 2007, the circuit court
granted appellees’ motion to quash appellants’ requested discovery, overruled appellants’
exceptions to the foreclosure sale, ratified the sale, and ordered that the matter be referred
to the co urt aud itor for a n acco unting .
On March 9, 2007, appellants noted an appeal from the ratification of the
foreclo sure sale , and m oved to stay enfo rceme nt of the ratificatio n of sa le pend ing app eal.
Appellants did not file a supersedeas bond with the motion. Appellees filed an opposition
to a stay of ratification pending appeal, and on March 15, 2007, the circuit court denied
appella nts’ mo tion.
On M arch 20, 20 07, appellan ts, pursuant to Maryland R ule 2-535 , filed a motio n to
alter or amend the judgment of ratification of sale, based upon the court’s revisory power
under subsection (a); fraud under subsection (b); and newly discovered evidence under
subsection (c). In that motion, appellants alleged that the foreclosure action was improper
becau se appe llees had violated the Tru th In Le nding A ct (TIL A), 15 U.S.C . § 1601 , et
seq., and the Real E state Se ttlemen t Proce dures A ct (RE SPA ), 12 U .S.C. § 2 601, et seq.,
and that, w ith additional d iscovery, appe llants could p rove the vio lations. App ellants
attached to the motion a packet of materials purportedly prepared by Linda J. Rougeux, an
“auditor” w ith “Advo cates for Ju stice” based in Abilene , Texas. Th e packet p urports to
represent the audit of a loan involving appellants and “IndyMac Ba nk,” but the terms are
very differen t from the te rms of the loan that is the subject of th is case. Mo reover, w hile
the audit purports to conclude that there are possible violations of federal law with respect
to the audited loan, the papers do not indicate the source of the information and do not
provide a conclusion under oath. Some of the papers appear to be form documents which
the organization presumably makes available to members of the public. Appellants also
attache d to the m otion an article pr omulg ated by th e “Cen ter for R espon sible Le nding,”
dated De cember, 2 006, conta ining data o n the “fore closure risk in the subprim e market”
and a copy of remarks made to the Congressional Black Caucus by a policy analyst at the
Center for Responsible Lending on the issue of sub-prime mortgage lending.
On March 23, 2007, appellees filed a response to appellants’ motion to alter or
amend the judgment. Appellees contended they were not involved in the mortgage
settlement with appellants and, therefore, were not liable for any potential violations of
federal mortgage laws; that appellants had not cited any authority providing that
violations of federal mortgage laws were a defense against foreclosure; and that
appella nts had not set f orth an y facts or e videnc e to sup port the ir claims .
On April 6, 2007, the circuit court denied appellants’ motion to alter or amend the
judgment of ratification of sale. On April 11, 2007, the third party purchasers of the
foreclosed property filed a motion requesting judgment awarding possession, and on May
2, 2007, appellants filed an opposition. On May 3, 2007, the circuit court entered an
order a wardin g posse ssion.
Additi onal fa cts will b e adde d as nec essary.
I. Ratification of the Fo reclosure S ale
On appeal appellants contend their two motions for injunctive relief from
foreclosure, one filed before and one filed after the foreclosure sale, were permitted under
Maryland R ule 14-20 9(b), and tha t they should ha ve prevaile d on the m erits. Appella nts
also contend they were entitled to further discovery at the time of the February 27, 2006
hearing, and the circuit court abused its discretion in quashing their notices of deposition
and subpoenas duces tecum. Finally, appellants contend they presented valid exceptions
to the foreclosure sale, although labeled as the second motion for injunctive relief, and
that the c ircuit co urt erred in ratifying the sale.
A. Injunc tion to S top Fo reclosu re Sale under Mary land R ule 14- 209(b)
The grant or denial of an injunction lies within the sound discretion of the trial
court, an d on ap peal, w e review the trial co urt’s dec ision fo r an abu se of d iscretion . See
Md. Comm’n on Human Relations v. Downey Commc’ns, Inc., 110 Md. App. 493, 521
(1996 ) (citation s omitte d).
A debto r who ow ns property su bject to a lien c reated by a lien in strument
possesses three means of challenging a foreclosure: “obtaining a pre-sale injunction
pursuant to Maryland Rule 14-209(b)(1), filing post-sale exceptions to the ratification of
the sale under Maryland Rule 14-305(d), and the filing of post-sale ratification exceptions
to the auditor’s statement of account pursuant to Maryland Rule 2-543(g), (h).” Wells
Fargo Home Mortgage, Inc. v. Neal, 398 M d. 705, 726 (2007) (citatio ns omitted); see
also Greenbriar Condo., Phase I Council of Unit Owners, Inc. v. Brooks, 387 Md. 683,
746-47 (2005 ). “In order to enjoin a sale pursuant to Md. Rule 14-209(b), the injunction
must be filed prior to the foreclosure sale. If filed after the foreclosure sale, the
injunction is in respect only to subsequent proceedings.” Brooks, 387 M d. at 738 .
In this case, ap pellants’ first req uest for an injunction w as not in com pliance w ith
Rule 14-2 09(b). Tha t subsection states, in part:
The mo tion shall not b e granted u nless the m otion is
supported by affidavit as to all facts asserted and contains: (1)
a statement as to whether the moving party admits any amount
of the deb t to be due a nd payable a s of the date the motion is
filed, (2) if an amount is admitted, a statement that the
moving party has paid the amount into court with the filing of
the motion , and (3) a de tailed stateme nt of facts, sh owing th at:
(A) the debt and all interest due thereon have been fully paid,
or (B) there is no default, or (C) fraud was used by the
secured p arty, or with the se cured party’s k nowled ge, in
obtainin g the lien .
Appellan ts’ motion d id not com ply with any of th e above re quiremen ts, and the co urt did
not err in failing to grant re lief.
Appellants second request for an injunction to stay foreclosure under Rule 14209(b) was filed after the foreclosure sale and, therefore, was untimely for purposes of
halting the foreclosure sale. Consequently, we shall direct our attention to appellants’
reques ts for dis covery a nd app ellants’ e xceptio ns to the sale.
B. Motion to Quash Discovery
We re view th e denia l of disc overy un der the a buse o f discre tion stan dard. Beyond
Systems, Inc. v. Realtime Gaming Holding Co., LLC, 388 Md. 1, 28 (2 005). A trial court
abuses its discretion only if no reasonable person would take the view adopted by the trial
court in denying discov ery. See id. at 28.
When ruling on exceptions to a foreclosure sale, Rule 14-305(d)(2) provides: “The
court shall hold a hearing if a hearing is requested and the exceptions or any response
clearly show a need to tak e evidenc e.” On the issue of disc overy related to exception s to
foreclosure sales, Gordon on Maryland Foreclosures explains:
There are, essentially, no real guidelines for the procedures
relating to exc eptions and , particularly, discov ery in
preparation for the hearing . On request, most C ircuit Court
judges will allow a reasonable period of time for depositions
and docu ment prod uction bef ore the hea ring, albeit
substan tially less tim e than in routine civil litiga tion.
Alexand er Gordo n, IV, Go rdon on M aryland Forec losures § 24 .2, at 1016 (4 th ed. 2004).
At the mo tions hearing , appellants req uested disc overy of the c losing doc uments
on the loan, including the original copy of the deed of trust, in order to show the loan was
usurious an d improp er. Appella nts claimed the original term s of the pro missory note
were altered after appellant signed the note, and that appellant was forced to pay $18,000
more th an wa s legally pe rmitted.
Appellants’ counsel also explained that appellants claimed they did not receive
proper notice of the foreclosure sale, and counsel requested discovery to determine
whether appellants received notice. Appellants’ counsel stated he had recently taken
appellants’ case, that prior to that appellants had been acting pro se, and that counsel had
not review ed the cou rt file by the time o f the hearin g and nee ded additio nal time to
conduct disc overy.
The circuit court noted appellants’ counsel made an appearance on behalf of
appellants on February 12, which gave him two weeks to prepare for the motions hearing
on Febru ary 27. Add itionally, the circuit co urt noted all o f the docu ments app ellants
sought for discovery were on public file, the only exception being the original deed of
trust, which appellees were not required to present to appellants in proceeding with the
foreclosure sale. The court then granted appellees’ motion to quash the notices of
deposition and subpoenas duces tecum.
Regardin g appellan ts’ request fo r discovery of the lending docume nts in order to
show the loan was usurious and improper, usury is not a proper ground for setting aside a
foreclo sure sale , and the questio n of us ury shou ld be co nsidere d at the tim e of the audit.
See Kirsner v. Sun Mortgage Co., 154 Md. 682, 688 (1928). Thus, the question of
whether the loan was usurious or improper was not relevant to the hearing on exceptions
to the sale, an d dis covery of the le ndin g docum ents was not n eces sary.
As to appellants’ request for discovery as to whether they had received actual
notice of the foreclosure sale, we agree with the circuit court’s finding that, upon entering
an appearance on February 12, appellants’ counsel had sufficient time prior to the
February 27 motions hearing to collect evidence on this issue. Moreover, appellants had
actual notice of the foreclosure proceeding, no later than November, 2006. Therefore, we
hold there was no abuse of discretion in de nying appellants additional time for disco very
and granting appellees’ motion to quash appellants’ notices of deposition and subpoenas
C. Exceptions to the Foreclosure Sale
Having failed to file a proper pre-sale injunction to the foreclosure sale under
Maryland R ule 14-20 9(b), appella nts’ next reco urse was to file excep tions to the sale
under Rule 14-305(d). In ruling on exceptions to a foreclosure sale and whether to ratify
the sale, t rial cour ts may co nsider b oth que stions o f fact a nd law . See S. Md. Oil, Inc. v.
Kamine tz, 260 Md. 443, 451 (1971) (explaining questions of fact and law may be raised
in exceptions to foreclosure sales). In reviewing a trial court’s finding of fact, we do “not
substitute our judgment for that of the lower court unless it was clearly erroneous” and
give due consideration to the trial court’s “opportunity to observe the demeanor of the
witnesses, to judge their c redibility and to pa ss upon th e weight to be given th eir
testimony.” Young v. Young, 37 Md. App. 211, 220 (1977). Questions of law decided
Appellants’ reference to Pacific Mortgag e & Investmen t Group, Ltd. v. Ho rn,
100 Md. App. 311 (1994), is unpersuasive. The discovery at issue in Horn was in the
context of a lawsu it by the borrower against the lende r and substitute trustee for statutory
violatio ns rega rding th e mortg age loa n, see id. at 317-18, and did not involve exceptions
to a fore closure sale.
by the trial court are subject to a de novo standa rd of re view. See Liddy v. Lamone, 398
Md. 2 33, 246 -47 (20 07).
After a foreclosure sale, a debtor’s right to redemption ends, however, a debtor
may file exce ptions challe nging on ly procedural irre gularities in the f oreclosure sale
Brooks, 387 Md. at 746, under Rule 14-305(d). Rule 14-305(d)(1) provides:
(d) Exceptions to Sale.
(1) How Taken. A party, and, in an action to foreclose a
lien, the holde r of a subo rdinate interes t in the prope rty
subject to the lien, may file exceptions to the sale.
Exceptions shall be in writing, shall set forth the alleged
irregularity with particularity, and shall be filed within 30
days after the date of a notice issued pursuant to section (c)
of this Ru le or the filing o f the report o f sale if no n otice is
issued. Any matter not specifically set forth in the
exceptions is waived unless the court finds that justice
The procedural irregularities might include: “allegations such as the advertisement
of sale was insufficient or misdescribed the property, the creditor committed a fraud by
preventing someone from bidding or by chilling the bidding, challenging the price as
unconscionable, etc.” Id. at 741. There is a presumption in favor of the validity of a
judicial s ale, and the bur den is o n the ex ceptan t to estab lish to the contrar y. See Jackson
v. Townshend, 249 M d. 8, 13-14 ( 1968) (citatio ns omitted); PAS Realty, Inc. v. Rayne,
46 Md. App. 445, 446 (1980) (citing Hardy v. Gibson, 213 Md. 493 , 508 (1957)).
Appellants raised a number of challenges in their motion opposing ratification of the sale,
as outlined above. The only challenge relating to procedural irregularities in the
foreclosure sale, however, was that appellees failed to send notice by registered or
certified ma il. The circuit co urt made th e followin g finding o n this issue:
I conclude that the trustees have as a matter of fact complied,
and I find as a fact that they have complied with the
expectations of [Rule 14-206(b)(1)-(2)]. That is to say, and
the timing contemplated by subsection 2B with regard to the
There’s evidence in the file here of the published
notices in the local new spaper. Th ere is eviden ce in the file
of the postal receipts attesting to or as evidence associated
with the af fidavits attesting to the mailing by first class mail
and certified mail.
The closest thing I’ve gotten to a proffer here is a
suggestion that Ms. Jo nes didn’t re ceive it. But th at flies in
the face of the actual history here where she must have
received so mething o r she wou ldn’t have a sking [sic.] u s to
enjoin the sale in the first place. So that suggestion is not, the
only factual proffer we have here is simply not supported by
the case history.
The court then denied appellants’ motion to stay ratification of the sale, ratified the
foreclo sure sale , and ord ered tha t the case be refe rred to a n audito r for an accou nting.
The record contains an affidavit by appellees, stating that they gave notice of the
foreclosure proceedings as required by Maryland Code (1957, 2003 Repl. Vol., 2007
Supp.) § 7-105 of the Real Property Article and notice of the foreclosure sale, by regular
and certified mail, advising app ellants as to the time, place, and terms of the foreclosure
sale. See Maryland R ule 14-20 6(b)(2) (bef ore sale, “the p erson auth orized to m ake sale
shall send notice of the time, place, and terms of sale by certified mail and by first class
mail to the last known address of . . . the debtor”). Attached to the affidavit are copies of
the letter t hat wa s sent to a ppellan ts and c opies o f the po stal rece ipts for th e mailin gs.
Appe llants ha ve not p resente d any evi dence to the co ntrary. Th e circuit c ourt did not err.
Appellants’ challenge on the basis of improper notice was the only procedural
challenge to the foreclosure sale and, thus, was the only proper exception to the
foreclosure sale. Therefore, we hold the circuit court did not err in overruling appellants’
exceptions to the foreclosure sale and ratifying the foreclosure sale.7
II. Motion for Stay of Enforcement of the Judgment Ratifying the Sale, Pending Appeal
Appellants contend the circuit court erred in denying their motion to stay
enforc emen t of the ju dgme nt ratifying the fore closure sale, pen ding ap peal.
[A] stay pending appeal is governed by Rules 8-422 through 8-424. If the
court determines that because of the nature of the action enforcement of the
judgment should not be stayed by the filing of a supersedeas bond or other
security, it may enter an an order denying a stay or permitting a stay only on
the terms stated in the order.
Maryland Rule 2-6 32(e).
A party against whom a judgment has been rendered may stay its enforcement by
filing a supersedeas bond that is in compliance with the requirements in Maryland Rule 8423. In a forec losure a ction, a s uperse deas bo nd mu st be file d. See Creative Dev. Corp.
v. Bond, 34 Md . App. 279 , 282-83 (1 976) (exp laining that w ith the excep tion of six
Appellants point out that, at the motions hearing, they discussed their then
pending complaint in federal court, in which they asserted violations of federal law, but
the circuit court failed to consider those allegations. The allegations did not constitute a
procedural challenge to the foreclosure sale and, therefore, were not proper exceptions
that cou ld have been ra ised at th e Febru ary 27 he aring.
specific actions, that do not include foreclosure actions, civil judgments cannot be stayed
unless a sup ersedeas b ond is filed); Onderdonk v. Onderdonk, 21 Md. App. 621, 623-24
(1974) (explaining parties must file a supersedeas bond when moving to stay enforcement
of judgment to ratify a foreclosure sale). Appe llants did not file th e nece ssary bon d.
It is well-settled law in Maryland that the rights of a bona fide purchaser of
mortgaged property would not be affected by reversal of the ratification of sale, in the
absenc e of a su persed eas bon d. Poku v. Friedman, ____ Md. _____ (filed January 10,
2008); Baltrosky v. Kugler, 395 M d. 468, 4 74 (20 06) (cita tions om itted). There are only
two exceptions to this rule: (1) unfairness or collusion between the purchaser and trustee
and (2) when the mo rtgagee purcha ses the d isputed proper ty at the fo reclosu re sale. Id. at
475 (ci tations o mitted).
There is no contention that the third party purchasers in this case are not bona fide
purcha sers, and no con tention t hat eithe r of the t wo ex ception s to the ru le apply.
Therefore, the court did not err in denying appellants’ motion to stay enforcement of the
judgment to ratify the sale.
III. Motion to Alter or A mend the Judgme nt of Ratif ication of S ale
Finally, appellants contend the court erred in not exercising its revisory power over
the judgment of ratification of sale under Maryland Rule 2-535. Appellants argue that the
court ab used its d iscretion becau se appe llants m ade a sh owing of frau d or irreg ularity.
We review the circuit court’s decision to deny a request to revise its final judgment
under t he abu se of d iscretion standa rd. See Mullaney v. Aude, 126 Md. App. 639, 666
(1999). The effect of a final ratification of sale is res judicata as to the validity of such
sale, exc ept in the case of fraud o r illegality. See Bachrach v. Wash. United Co-op., 181
Md. 315, 320 (1943); Manigan v. Burson, 160 Md. App. 114, 120 (2004) (citations
omitted). The burden of proof in establishing fraud, mistake, or irregularity is clear and
convin cing ev idence . See Billingsley v. Lawson, 43 Md. App. 713, 718 (1979). To
establish frau d under R ule 2-535 (b), a mova nt must sho w extrinsic fraud, not in trinsic
fraud. See Manigan, 160 M d. App . at 120 ( citations omitted ).
This Co urt explaine d the distinctio n betwee n intrinsic frau d and extrin sic fraud in
[A]n enrolled decree will not be vacated even though obtained
by the use of forged documents, perjured testimony, or any
other frauds which are “intrinsic” to the trial of the case itself.
Underlying this long settled rule is the principle that, once
parties have had the op portunity to pres ent before a court a
matter for investigation and determination, and once the
decision has been rendered and the litigants, if they so choose,
have exhausted every means of reviewing it, the public policy
of this S tate dem ands th at there b e an en d to that l itigation . . .
[.] This policy favoring finality and conclusiveness can be
outweighed only by a showing “that the jurisdiction of the
court has been imposed upon, or that the prevailing party, by
some ex trinsic or collatera l fraud, has p revented a fair
submi ssion o f the co ntrove rsy.”
Billingsley, 43 Md. App. at 719 (quoting Schwartz v. Merchs. Mortgage Co., 272 Md.
305, 30 8-09 (1 974)).
Fraud is ex trinsic whe n “it actually prev ents an adv ersarial trial but is intrin sic
when it is employed during the course of the hearing which provides the forum for the
truth to appear, albeit, the truth was distorted by the complained of fraud.” Manigan, 160
Md. App. at 121 (quoting Billingsley, 43 Md. App. at 719). Irregularity under Rule 2535(b), is de fined as:
[“]the doing or not doing of that, in the conduct of a suit at
law, which, conformable to the practice of the court, ought or
ought not be to be done.” (citation omitted) “As a
consequence, irregularity, in the contemplation of the Rule,
usually means irregularity of process or procedure . . . , and
not an error, which in legal parlance generally connotes a
departure from the truth or accuracy of which a defendant had
notice and could have challenged.” (citation omitted)
Manigan, 160 Md. App. at 121 (quoting Billingsley, 43 Md. Ap p. at 720).
In their motion, appellants made general allegations that appellees violated TILA
and RESPA, and contended that with additional discovery they could prove such
violations. Appellants attached a document, described as an audit report, but which
pertains to a mo rtgage lo an that d oes no t involv e appe llees and is unrela ted to thi s case.
Appellants also attached a public policy report that presented empirical data on sub-prime
mortgag e len ding , as w ell as remarks mad e to th e Co ngre ssional B lack Cau cus b y a
policy analyst at the Center for Responsible Lending on the issue of sub-prime mortgage
lending. Appellants’ motion contained no probative evidence showing extrinsic fraud or
irregula rity in the fo reclosu re sale a nd did n ot prese nt new ly discove red evid ence. W e
hold the circuit court did not abuse its discretion in not exercising its revisory power over
the judg ment to ratify the f oreclos ure sale .
In conclusion, we note that we are not unaware of the issues that exist with respect
to subprime mortga ge lending, and that som e persons believe that curren t foreclosure
proced ures do not pro vide de btors w ith suff icient op portun ities to ch allenge foreclo sure.
Assum ing, arguendo, that that belief has merit, a debtor does n ot advance the deb tor’s
cause by filing documents that do not comply with the Maryland Rules, are incomplete,
inaccurate, a nd mislead ing. Becau se we ha ve seen so me of the same “fo rm” docu ments
in other foreclosure cases, in which the debtor, as here, acted pro se, we assume that
someone (not appellants’ current counsel) has provided bad advice and bad
docum entation .
We hold the circuit court did not err (1) in denying appellants’ requests for an
injunction to stop the foreclosure sale, (2) in granting appellees’ motion to quash
appellants’ notices of deposition and subpoenas duces tecum; (3) in overruling appellants’
exceptions to the foreclosure sale and in ratifying the sale; (4) in denying appellants’
motion for a stay of enforcement of the judgment ratifying the foreclosure sale, pending
appeal; and (5) in denying appellants’ motion to alter or amend the final judgment of
ratificatio n of sa le.
JUD GM ENT S AF FIRM ED.
COSTS TO BE PAID BY
APP ELL ANT S.
In the United States District Court
For the District of Maryland
NOV 1 7 2005
DIST""" 01' IINlYlANO
No'JllT DI;PO~I'r Bel:
Tanya and Donna Jones
12109 Crestwood Tum
Brandywine, MD 20613
EMC Mortgage Company
P.O. Box 141358
Irving, Texas 75014-1358
Mortgage Electronic Registration System, Inc.
P.O. Box 202
Rosenberg & Associates, LLC
7910 Woodmont Avenue, Suite 750
Bethesda, Maryland 20814
GreenPoint Mortgage Funding, Inc.
P.O. Box 908
Newark, NJ 07101-0908
(Breach of Contract, Fraud)
Now comes Plaintiff, (fanya and Donna Jones) (herein after "plaintiff') Pro Se and
complains as follows;
I. "This court has jurisdiction pursuant to diversity of citizenship in accordance
with the Federal Rules of Civil Procedures.
-- - - - - - - - - - - ' 1
2. This court has jurisdiction as the amount in controversy exceeds $50,000.00
in accordance with Federal Rules of Civil Procedures.
3. During all times mentioned in this complaint, Plaintiffwere residents of the
State of Maryland and resided at 12109 Crestwood Tum in Brandywine, MD
4. EMC Mortgage Company, it's agents and co-parties (defendants), was the
Mortgage company licensed to do business in the state of Maryland, whose
business address is P.O. Box 141358 Irving Texas 75014-1358.
Breach of Contract
5. Date of Settlement, August 31, 2005.
6. Facts; their inability to validate the alleged debt and subsequently attempted to
coerce payment is also creating a commercial injury.
a.) If "Lender" does not provide verification and! or adequate
assurance ofthe alleged debt as herein requested pursuant to
the laws of the land, and any debt allegedly owed by me is
extinguished as an operation oflaw. An obligation once
extinct, it never revives again. "OGDEN v SA UNDERS. 25
U.S. 213 (1827)
7. A notice sent pursuant to the FDCPA, Title 15 U.S.C. 1692g Section 809(b)
that your claim is disputed and validations is requested.(EEOC V Shell Oil Co.
466 U.S. 54, 76 n. 32 (1984) and Edelman V. Lynchburg College. S. Ct. May
b.) Until the debt is validated the defendant and it's co-parties
shall cease collection of the alleged debt and they must show
positive proofthat you owe them some money and it should
not be a computer generated printout of the debt. The
Defendant continued to try and collect the alleged debt during
the entire validation process.
8. Plaintiff sent various letters ofvalidation to Defendant via certified mail.
Defendant was non-responsive to all letters mailed. To date Defendant has
failed to comply otherwise. By and through acquiescence, silence is known as
agreement of understanding by parties to consent judgment without further
a.) The initial letter of validation was made on January 26, 2006
b.) On February 15,2006 another letter was mailed to Defendant
c.) On March 8, 2006 another letter was mailed to Defendant
d.) On March 28, 2006 yet another letter was mailed to Defendant
e.) On April 18, 2006 another letter was mailed to Defendant
f.) On May 22, 2006 another letter was mailed to Defendant
informing them that they were in Breach of the Contract
g.) On June 15,2006 a Notice of Default was mailed to the Defendant
9. Any collateral attack on this agreement/contract is in Bad faith and is an
attempt to violate the U.S. Constitution, Article 1, Section 10.
10. EMC Mortgage Company and its Agents is not the holder in due course.
a.)The Defendant and its agents are required to give proof of
claim! verification of the purported debt and status as holder
is due course. Such is required as a matter of due process
oflaw. (Morris V. Jones 329 U.S. 545 (1947)
11. Plaintiffs promissory note was deposited into said customer transaction
account, creating new money and increasing the assets of EMC Mortgage
Company and then issued a check drawn on the customer transaction that
contained the new money, there by zero balancing the ledger on the plaintiffs
customer transaction account.
12. Pursuant to Generally Accepted Accounting Principles (GAAP), plaintiffs
should now be paid for their promissory note when endorsed pay to the
order without recourse.
13. The Defendant is indebted to Plaintiffs in the amount of the promissory
note. The defendant never issued a receipt to the Plaintiffs for the promissory
note and it has never been recorded.
15. The Defendants have made false and fraudulent entries into specially coded
files such as Customer Transaction accounts that courts rely upon as
16. Defendant violated contract law by not property disclosing Yield Spread
Premium (fraud in the factum), the Plaintiff was prevented from understanding
the basic nature of the bargain when the broker and defendant failed to
properly disclose the Yield Spread Premium and what it would ultimately
mean to the Plaintiff and the interest rate.
17. Defendant failed to acquire a UCC-I on the property as required and in
contravention ofArticle 9 of the UCC.
a.) The Plaintiffs must sign the UCC-I for the original and each time
the note is sold the Plaintiffs must sign again for each new assignee.
b.) Defendant failed to provide that the Plaintiffs signed papers
acknowledging receipt ofthe UCC-llien.
18. Plaintiffs are no longer liable for additional charges pursuant (GAAP).
19. Defendant sold promissory note to a third party, while requiring plaintiff to
submit monthly payments that were not due or owed.
20. Defendants have never made a assessment or signed an Assessment Certificate
under penalty of perjury, true, correct, complete and not misleading.
21. Defendant never risked any of its funds in the purported loan transaction.
Wherefore, the plaintiffpray this Honorable Court award judgment in the amount of
Five Hundred and Fifty Thousand dollars (550,000.00) plus interest, filing fees and other
court costs for unjust enrichment.
Violations ofTruth in Lending Act (TILA)
22. Plaintiff does not need to prove that the lender intended to violate the TlLA in
order to prove a violation (Wright v. Tower Loan ofMississippi, Inc. 679 F. 2d
436,445 j'h Cir. 1982)( Mills v. Home Equity Group, 871 F. Supp. 1482, 1485
86 D.D.C. 1994)
23. Defendant failed to provide a copy of the appraisal in the loan documents
a.) Defendant failed to provide that the appraisal meets
FNMA/FHLMC standards for establishing value per
FNMA/FHLMC MRl's1ALL Regsll 2 USC §3349(a)(l) (2)
b.) Defendant failed to provide that appraiser meets licensing
requirements (1,000,000 < State Certified) per 12 USC
§3342(l) or (2) and §3350 (5) (A) (B) and (C)
24. Defendant failed to provide that the finance disclosure fOIro has an OMB
number, Title 12 and 31 U.S.C. §1901.
c.) Defendant failed to provide that either the Note or Mortgage
had a valid OMB number. (Paperwork Reduction Act of1995)
d.) Defendant failed to provide a complete copy of all loan
documents signed by both the lender and the borrower within
three days of consummation, both the lender and the borrower
must sign the Note and Mortgage or Deed of Trust.
25. Defendant failed to provide a separate sheet for each of the charges
summarized on the Good Faith Estimate.
26 .Defendant failed to provide to the Plaintiffs a settlement statement disclosing
interest rate. Violation: Pursuant Title 12 Code of Federal Regulation, Section
27. Defendant failed to provide the Plaintiffs with a notice of right cancel or
rescind in their mortgage documents and it must be two copies for each
borrower. Violation: Regulation Z §§265.5 (a) (1) and 226.1 7(a)(1). 15 USC
226.15 (b) and 226. 23 (b).
28. Defendant failed to provide to the Plaintiffs a right to cancel signed by both
parties. Violation: Pursuant 12 Code of Federal Regulations, §226.18 et seq.
29. Mortgage lenders who failed to provide disclosures prior or at time of signing
contrary to TILA is a UDAP violation. Hill v. AI/right Mortgage Co., 213 B.R.
30. The mortgage lender failed to provide that certain disclosures were clear and
conspicuous. Various documents among the loan papers were confusing.
Violation Equal Credit Opportunity Act Codified to 12 C.F.R. §202.1
The Court reserves the right to condition rescission
If there are two or more homeowners who are borrowers, each one must receive two
copies ofthis notice. If the lender does not provide two copies of the Notice of Right to
Cancel at the time the loan is signed each homeowner borrowing against his or her home,
each homeowner has the right cancel the loan for three years after he or she has signed
the papers. Violation: Regulation Z §§ 226.5 (a)(l). 15USC 226. 15(b) and 226. 23(b)
31. Defendant violated 12 USC §2604 et seq.
A.15 U.S.C. §§ 1604(b), 1638(b)(l); RegulationZ,12 C.F.R. §§
226.18 et seq.
B. 15 USC Section 1638(a)(2)(B), (a)(9), (a)(II) and (a)(12) and
Regulation Z, Part 226.17 et seq.
C. 12 U.S.C. 2601-17, RESPA Section 8, (24 CFR 3500.21)
a) The Defendant gave a kickback to the broker violating
RESPA and Unfair Deceptive Trade Practices.
b) The Defendant paid the Yield Spread Premium to the
Broker in exchange for the Broker selling an increased
interest rate to the borrower (the broker was paid
c) The Defendant should require invoices for all appraisals
And processing fees due to be paid out to third parties.
There is no invoice for the 790.00 processing fee paid to
the broker on the HlJD..l.
CRIMINAL AND CIVIL LIABILITIES UNDER TlLA AND RESPA
The Defendant willingly and knowingly failed to comply with the requirements of the
TILA and should be fined not more than 5,000.00 per violation or imprisoned not more
than one year,or both. TlLA section 112. The Defendant should also be held liable to the
Plaintiff for actual damages and court cost and for other damages arising out of
individual or class action if certain requirements of the TILA were violated. TILA section
130 and 131. A Creditor may be held liable to a consumer for Failure to comply with
RESPA Section 8 Prohibitions, Regulation X, 24 CFR 3500 re kickbacks and unearned
fees: (I) a fine of not more than $10,000.00 or imprisonment for not more than one year,
or both; (2) civil liability equal to three times the amount of any charge paid for such
settlement service; and (3) court cost and attorney fees. Under Title 15 USC § 1601(a)
any consumer harmed by a violation of TILA may bring a suit against the lender.
Generally TILA provides for the following remedies; (1) actual damages (2) damages
Twice the amount of any finance charge in connection with the transaction (3) damages
Not less than $200 or greater than $2000 for each violation (4) attorney's fees.
Plaintiff request a trial by jury guaranteed by both state and federal constitutions. Bill of
Rights Amendments VIL
Prayer for Relief
Wherefore, the plaintiff demand judgment:
A. Awarding plaintiff one million dollars (1,000,000.00).
B. Awarding plaintiff the reasonable costs, including interests, court costs, and
legal fees for this action.
C. And awarding plaintiffs punitive damages in the amount of One Million
D. Granting Plaintiff such other and further relief as may be just
12109 Crestwood Tum
SILVER SURETY BOND # TLJ10693
County of Prince George's
State of Maryland
I, Tanya Lorraine Jones, do hereby enter myself security for the costs in the
cause, and acknowledge myself bound to pay cause to be paid (effect payment)
all costs which may accrue in such actions upon proof of claim and proof of loss
to any party injured by any UNBONDED claim presented against (TANYA
LORRAINE JONES ). And, I (Tanya Lorraine Jones) underwrite with my private
exemption(Tanya Lorraine Jones) (261597522), all such costs that may be
Dated this 15th day of October, 2006
dMur non damnitlc8to
JUSTIFICATION OF SURETY SUBROGATION
County of Prince George's )
State of Maryland
Personally appeared this day before meL~~"'lI'f5 JONt:...5 of the County and State
aforesaid, surety on the bond of Tanya Lorraine Jones, being duly swom, deposes and
says that he is seized of his right mind, and that over and above all of her just debts and
liabilities, in property not exempt by law from levy and sale under execution, of a clear
unencumbered estate of the value in the excess of (unlimited), within the jurisdiction of
this State and/or the District of Columbia. .
Subscribed and sworn to before me Nl\cl
in Prince George's, Maryland State. On the
Notary Public Seal
,a Notary Public residing
day of October, 2006
12109 Crestwood Tum
Brandywine, Maryland 20613
(Tanya Lonaine: Secured Party)
(County of Prince Georges)
(state of Maryland)
(United States of America)
(.-Tanya Lorraine Jones) Only in capacity as beneficiary to the Original Jurisdiction
NOTICE OF SURETY ACT Al '4D BOND
Re: UCC Contract Trust Account number 261-59-7522
KNOW ALL MEN, BY TIlESE PRESENTS; I, (:Tanya Lonaine Jones),
Principal,Titled Sovereign, neutral, surety, guarantor, a free man upon the free soil of
(Maryland), state that I am not a corporation, am a living being, of legal age, competent
to testi &, have personal first-hand knowledge of the truths and facts stated herein as
being true, correct, complete, certain, and not misleading.
I, (:Tanya Lonaine Jones), of my own free will and accord, in the presence of
Almighty God, in capacity as beneficiary to the Original Jurisdiction, in good conscience,
do willingly undertake to act as surety, to pledge and provide private bond, in the amount
oftwenty-one Dollars coinage, minted by the American Treasury (at the legal and lawful
24 to 1 ratio prescribed by law) united States ofAmerica, Lawful coin dollars of the
united States of America, personally held in my ownership and possession. This
undertaking is in accordance with Article VII in the Bill of Rights of the Constitution of
the United States.
This bond is to the credit of the private part listed hereon, (:Tanya Lorraine Jones)
capacity as beneficiary to the Original Jurisdiction, by his appellation, as full faith and
credit guarantee to any Lawful Bill in redemption, duly presented under Seal in Lawful
specie money of the account of the untied States of America, Original Jurisdiction, to wit,
pursuant and in parity to the cost-expense ration of senate bill 760 on fill with this State.
The Bill of Redemption is a tender as set off for any alleged contract, agreement,
consent, assent purportedly held, as an obligation of duty against (:Tanya Lorraine Jones)
so as to cause an imputed disability, or presumption against the capacity, Rights and
powers of (:Tanya Lonaine Jones). The specific intent of the bond, under seal, is to
establish, by My witness, the good credit and Lawful money specie of (:Tanya Lonaine
I, (:Tanya Lorraine Jones), do make this surety, pledge, bond, under My seal, as
full faith and credit guarantee, to any Lawful Bill, duly presented, to Me under Seal,
under penalties ofperjury, in Lawful money of account of the united States of America,
PUBLIC NOTICE AND SURETY BOND
cc: Director afthe Mint
in the matter of correct public judicial/corporate actions in the forum of Original Rules.
Original Jurisdiction, for the benefit and credit of the peculiar private party
listed above and their hein and assigos.
The intent of the bond, under Seal, is to establish, by My witness, the good
credit, in the sum certain amount of at least twenty-one dollan in silver coinage,
which carries no debt obligation worldwide, minted by the American Treasury,
united States of America, Lawfullpecie doUan of the united Statts of America,
available to the bond the actions of the private party listed above, and further, in
reservation of Rights UDder common law and customs of the united Statts of
America, Original Jurisdiction, Original Rules, has, before this assembly of Men, a
bond in tender of twenty-one DoDan Silver, Coinage Act of A.D. 1792, Bond of
Identity and Character OAS proof positive, competent evidence, (:Tanya Lorraine
Jones,)cannot be bankrupt, the causa debendi, not cessio bonorum. or ajorma
pauperis, dolus trust (f ANYA WRRAINE JONESlOTM ).
The life of this bond coven elVe (5) yean from the date entered below unless
the claimant enten a true bill of particulan and aD related causes of action and
advice of counsel (who claimant works for?) and information with testamentary
documentation UDder the penalties of perjury per Title 26 USC 606S into evidence
in the case of the peculiar private party listed above, in which case the life of the
bond will be eItended for a period of two (2) yean after such documentation is
presented under the penalties of perjury per Title 26 USC 606S in the case of the
peculiar party listed above, whereby, by the signature Jurat and Seal of (:Tanya
Lorraine Jones,), in capacity as beneficiary of the Original Jurisdiction, surety,
guarantor herein confirms, attests, and affirms this bond. AD assumptions and
presumptions have to be proven in writing, signed and sealed before three witnesses
as a valid response, if any.
Upon failure of response required UDder the three (3) day grace period under
Truth in Lending, Regulation Z, to respond and rebut, point for point, this Notice of
Surety Act and Bond, from receipt, UCC Section 1-204, unless a request for an
extension of time is presented in writing, claimant is hereby coDateral1y estopped
from any further advenarial actions against the peculiar private party listed above,
and for good cause not limited to the laws of coDateral estoppel, coercion, fraud and
want of subject matter jurisdiction, the peculiar private party listed above demands
that the caule(S) be vacated, dismissed and the accounts be immediately discharged
with prejudice. A lack of response or rebuttal under the penalties of perjury means
claimant assents to this Notice of Surety Ad and Bond and that a fault eDsts, UCC
Section 1-201 (16), creating fraud through material misrepresentation that vitiates
all forms, contracts, testimony, agreements, etc. express or implied, from the
beginning, UCC Section 1-103, of which claimant may rely on, and there is no
longer permission by consent or assent for any demand of payment being ordered or
levied against the peculiar private party listed above; and the peculiar private party
listed above further demands that the record be eIpunged and the records and facts
PUBLIC NOTICE AND SURETY BOND
cc: Director of the Mint
oftbe above attacbed captioned federal agency for tbeir investigation of violations of
federal law and any interlocking agencies, et al. Failure to comply punuant to tbe
Trutb in Lending Act will negate all remedies for claimant.
Any Third Party compelled to serve will make claimant liable for civil and
criminal prosecution in accordance witb tbe Erie aod Clearfield Doctrines.
NOTICE TO THE PRINCIPALS IS NOTICE TO THE AGENTS
NOTICE TOT HE AGENTS IS NOTICE TO TIlE PRINCIPALS
Done this the 17th day of the October month, anno Domino, in the year of our Lord, two
thousand, and six
acity as beneficiary ofthe Original Jurisdiction
All RIGHTS RESERVED WITHOUT PREJUDICE, UCC 1-308
County of Prince Georges)
(State of Maryland)
(:Tanya Lorraine Jones known by Me or made known for Me by proper
identification and duly sworn, Certified, Verified, and Exemplified, pursuant to
applicable state status this 17th day ofthe October month, in the year of our Lord, two
t:ousand and SiX:.
My Commission Expires:
PUBLIC NOTICE AND SURETY BOND
cc: Director oftbe Mint
P,PfWloA ~ C
INTERNATIONAL BILL 0
XCHANGE (liNCITRAL Convention)
PURSUANT TO AND IN ACCORDANCE WITH FINAL ARTICLES OF THE UNCITRAL CONVENTION IN EFFECT ON THE DATE HEREOF.
REF: Ratified Convention Artides 1-7, 1112, 13,46-3, 47-4(c), 51
For International/Interstate and Cross-Border Transactions.
Registered Mail # RB 503 231 537 US
PUBLIC POLICY DOCUMENTARY DRAFT ISSUED BY A PRIVATE UNINCORPORATED NATIONAL BANKING ASSOCIA'nON
.;ui1.~·arte~('1 i.~q;.~l 'eqris:" !.·lbl;~:F)ti~I:.: . . ~t th~:~ :~ . ')I"pCJr;jtt- ,JNITED STt,TES
legal Tender for An Debts, PUbic Charges, Ta,es and Dues payable without Deductions 101 and Free of any Levy, Duties. or Impost of any nalure in UNITED STATES DOLlARS (USD).
PRESENT DIRECTLY TO THE COLLECTING PARTY WITH DOCUMENTS. ACCEPTANCE FOR HONOR TO CREDIT ON SIGHT.
RECORDED / REGISTERED / CERTIFIED FUNDS No. (UCC3 No. O'JO(!C'(!(; Ii<1 ;'[i4nl)
DOCUMENT No, 106913
PER GUARANTEE OF U,C,C. CONTRACT UNITED STATES TREASURY PRIORITY PREPAID EXEMPT ACCOUNT J BOND No. E95523290
CREDIT UPON SIGHTTO PAYEE:
JOHN VELLA EMC MORTGAGE COMPANY ACCOUNT #0014109946
2780 Lake Vista Drive Lewisville, TX. 75067
SECRETARY OF THE TREASURY OF THE UNITED STATES
OR OTHER AUTHORIZED REPRESENTATIVE OF THE UNITED STATES
THRU ENS LEGIS U.S. CITIZEN,TRUST
BILL OF EXCHANGE
(an obligation ofthe United States)
Presented For Acceptance On Demand
REMIT AT PAR VIA FEDWIRE
EMC MORTGAGE COMPANY
TO THE ORDER OF
US $ 227,273.78 USD
IN THE SUM CERTAIN AMOUNT OF: Two Hundred Twenty Seven Thousand Two Hundred Seventy Three 781100T!..