Memorandum in Support of Motion to Dismiss
Content
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA BANKUNITED, as [purported] successor in interest to [failed] BANKUNITED, FSB., Plaintiff, vs. JENNIFER FRANKLIN-PRESCOTT, et al., Defendants. ___________________________________________________________________/ “MOTION-TO-DISMISS”-MEMORANDUM, CH. 71, FLORIDA STATUTES NOTICE OF SERVICE OF PLEADING(S) UPON ERIN M. ROSE QUINN CASE NO.: 09-6016-CA
FAILURE TO SET FORTH TIME AND MANNER OF FAKED “LOSS” 1. Violative of § 71.041(5), the purported Plaintiff failed to set forth: “the time and manner of loss or destruction”. FAILURE TO ATTACH “SUBSTANTIAL COPY” 2. Violative of § 71.041(5), the purported Plaintiff failed to attach: “a substantial copy of that lost or destroyed”, because admittedly, “the time and manner of loss or destruction” and that “lost or destroyed” were “unknown”. 3. Because the purported Plaintiff did not know “Counsel”, “that lost of destroyed”, and “the time and manner of loss or destruction”, the purported Plaintiff also failed to set forth and/or ascertain
“that the persons named in the complaint are the only persons known to plaintiff who are interested for or against such reestablishment”. See § 71.041(5), Fla. Stat. NON-COMPLIANCE AND FAILURE TO REESTABLISH ANY PAPER 4. Therefore here, the purported Plaintiff failed to comply with Chapter 71, Fla. Stat., did not reestablish any paper, and could not possibly reestablish any paper. Thus, the allegations were absolutely non-meritorious, and the Complaint shall be dismissed. TROUBLED FOUNDER OF FAILED BANK WAS NOT “COUNSEL” 5. Troubled Alfred Camner, founder of bankrupt “BANKUNITED, FSB”, is not appearing for the purported Plaintiff. 6. The Docket entry dated “02/22/2010” fraudulently misrepresented: “Notice of Appearance as Co-Counsel by Erin M. Rose Quinn on behalf of Plaintiff”. Here, no other known “Counsel” appeared to represent the purported Plaintiff at that time. 7. In particular, Alfred Camner, and the Attorneys with troubled Camner Lipsitz under its founder Camner, are not representing the Plaintiff. Here, “Erin M. Rose Quinn’s” record misrepresentation appeared to be in bad faith and for deceptive purposes. While the troubled bank’s failure had been evident for a very long time, the failed bank’s founder Alfred Camner took improper and facially non-meritorious action against Jennifer Franklin Prescott. DECEPTION 8. Here, no authentic Promissory Note and/or Mortgage had ever existed. Therefore here admittedly, no such Note or Mortgage could have possibly been “in the custody or control of” the failed bank. Because troubled founder of the failed bank and Attorney Alfred
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Camner had a conflict of interest, Camner and Camner Lipsitz pleaded lack of any knowledge and control. 9. No secondary or any other evidence existed, because failed bank founder Camner could not establish any “loss”. Troubled bank founder Camner did not know what he had “control of”, and therefore, the bank failed. FAILED “BANKUNITED, FSB” ADMITTEDLY FABRICATED “MORTGAGE” 10. Bankrupt “BANKUNITED, FSB”, the purported “Plaintiff”, admitted the record absence of any interest and/or “promissory note” in its “custody or control”: “6. Said [non-existent] Promissory Note and Mortgage have been lost or destroyed and are not in the custody or control of BANKUNITED, and the time and manner of the loss or destruction is unknown.” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 3. FAILED BANK’S FAILURE TO SATISFY “REQUIRED CONDITIONS” 11. Bankrupt “BANKUNITED, FSB.”, a.k.a. “BANKUNITED, FSB”, and/or “BANKUNITED” failed to satisfy “conditions precedent to the institution of” this action. Id., p. 2. FAILED BANK’S FRAUDULENT PRETENSES ON THE RECORD 12. “Plaintiff” failed bank fraudulently pretended that the “conditions precedent to the institution of” this facially fraudulent action “occurred” and/or had “been performed or excused”. 13. Here, said bankrupt bank, Camner Lipsitz, and/or the dismissed firm’s founder Alfred Camner did not comply with the Fair Debt Collection Practices Act. LACK OF GOVERNMENT AND/OR JUDICIAL AUTHORITY TO FABRICATE ‘LOAN’ 14. Jennifer Franklin Prescott, who is a European citizen, holds unimpeachable title to her publicly recorded homestead in Naples, Florida, U.S.A.
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15. For claims asserted in Federal Court against the presiding Judge, Jennifer Franklin Prescott (“Prescott”) does not submit to the jurisdiction. 16. Neither the Defendant presiding judge nor any judge had any official right or Government authority to fabricate, re-fabricate, and/or “re-establish” that which had never existed. Id. PUBLIC RECORD OF BANKRUPT “PLAINTIFF’S” FRAUDULENT HISTORY 17. Purportedly on behalf of “Plaintiff” bankrupt bank “BANKUNITED, FSB”, and/or “BANKUNITED”, law firm Camner Lipsitz filed a prima facie fraudulent “complaint” against Prescott. RECORD DECEPTION, TRICKERY, FRAUD 18. Here, the purported “Plaintiff’s” designations were deceptive and for the unlawful purpose of misleading the public and property owners. 19. Here, purported “Plaintiff” “BANKUNITED, FSB” had failed. The bankrupt bank had been founded and mis-managed for most of its troubled history by Alfred Camner, the head of reportedly dismissed Camner Lipsitz. 20. A Federal shareholder class action lawsuit had targeted said Defendant Alfred Camner and other former players at the bankrupt bank, who had allegedly deceived investors about the quality of the bankrupt bank’s loan portfolio. 21. Here, Defendant Camner’s outfit did a “significant amount of work” for “Plaintiff” bankrupt “BANKUNITED, FSB”, while signs of the bankrupt bank’s failure had been evident for a very long time. 22. Private equity players “formed” another “BANKUNITED” to play with the assets of the failed bank, and Alfred Camner and Camner Lipsitz were reportedly dismissed pursuant to
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the record. The failed bank and the law firm have a dispute over legal fees pending in MiamiDade County Circuit Court. The bank reportedly posted a $3 million bond in that case. 23. Here, BANKUNITED itself could no longer have any confidence in troubled original founder Alfred Camner and his failing outfit Camner Lipitz and thus dismissed said judicial officers. 24. Here after said dismissal of Camner Lipsitz, attorneys of said firm had no authority to appear and perpetrate fraud on this Court. FAILED BANK FAKED “INTEREST” 25. Here as a matter of law and public record, failed “BANKUNITED, FSB” has been defunct. In this case, no “mortgage” had ever been “in the custody or control of” bankrupt “BANKUNITED, FSB”. 26. Here, “BANKUNITED” could not possibly be any “successor in interest” and/or holder of any interest in Prescott’s record homestead, because bankrupt “BANKUNITED, FSB” had never acquired any interest of record. Here pursuant to the record, BANKUNITED, FSB went bankrupt, and no valid “mortgage” had existed. 27. Admittedly “the time and manner of the loss or destruction is unknown”, because no “mortgage” had ever existed, and the “Plaintiff” failed bank fabricated “loss” and/or “destruction”. Because no “mortgage” had ever been “in the custody” of bankrupt “BANKUNITED, FSB”, the sham “action” is facially frivolous and fraudulent. 28. Here, the failed “Plaintiff’s” fabricated “interest”, “promissory note”, and/or “mortgage” had never existed. The Plaintiff bank and founder’s law firm fraudulently concealed “manner and time” of the fabrication of the failed bank’s and/or law firm’s fictitious “promissory note”. BANKRUPT BANK FABRICATED “DAMAGES”
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29. Here, the “Plaintiff” bankrupt bank fabricated “damages that exceed $15,000.00 …” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 2. PRIMA FACIE FRIVOLOUS & FRAUDULENT “CLAIM” 30. Here, the bankrupt “Plaintiff” and/or court could not possibly “reestablish” and/or (re-) fabricate that which admittedly had never existed. DEFUNCT BANKUNITED, FSB., PERPETRATED FRAUD ON THIS COURT 31. Here, defunct bank “BANKUNITED, FSB.” perpetrated fraud upon this court and acted in bad faith. The “Plaintiff” bankrupt bank is liable for damages and expenses. BANKRUPT BANK’S TRICKERY & DECEPTION - EXHIBITS 32. Here therefore, the bankrupt bank’s “Exhibit(s)” of a non-existent and purportedly “lost” and/or destroyed “mortgage” were deceptive. 33. Here, there was no evidence to support any “lis pendens”. 34. Here admittedly, no valid evidence of any interest in the name of the bankrupt bank could have possibly existed, and the failed “Plaintiff” bank perpetrated prima facie fraud on the record. WHEREFORE, Jennifer Franklin Prescott demands 1. An Order dismissing the Complaint for impossibility to reestablish a non-existent purported paper; 2. An Order enjoining said deceptive misrepresentation of Plaintiff’s counsel; 3. An Order clarifying who is truly representing failed “BANKUNITED”; 4. An Order dismissing the purported “action” as facially fraudulent and frivolous; 5. An Order dismissing this facially fraudulent action, because a non-existent “instrument” cannot possibly be “reestablished”, “re-faked”, and/or (re-)fabricated as a matter of law;
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6. An Order dismissing this facially fraudulent action, because “Plaintiff” bankrupt bank never was “in the custody or control” of any valid “mortgage” before the bank failed and defrauded property owners and/or investors on the record; 7. An Order for sanctions and expenses against “Plaintiff” bankrupt bank “BANKUNITED, FSB” and its dismissed and/or fired attorneys at Camner Lipsitz; 8. An order removing the fired judicial officers with the Camner Lipsitz firm from these proceedings, and striking their fraudulent pleadings, because they perpetrated said record fraud and fraud on this Court and in particular, fraudulently pretended a lost and/or destroyed “mortgage”. ________________________ /s/Jennifer Franklin Prescott Victim of bankrupt BANKUNITED, FSB’s record fraud and fraud on this Court Victim of failed BANKUNITED founder Alfred Camner’s record fraud & fraud on this Court EXHIBIT: Docket
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7/23/2010
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Style: BANKUNITED vs FR ANKLIN-PR ESC O TT, JENNIFER Uniform Case Number: 112009C A0060160001XX Clerks Case Number: 0906016C A Court Type: CIRCUIT C IVIL Case Type: MO R TGAGE FO R ECLO SUR ES Judge: HAYES, HUGH D Case Status: O PEN Next Court Date: Last Docket Date: 07/09/2010 Disposition Judge: Disposed: Reopen Reason: Reopened: Reopen Close: A ppealed: Filed: 07/09/2009
Parties Name
Dockets
Events
Financials Type PLAINTIFF PLAINTIFF PLAINTIFF'S ATTO R NEY PLAINTIFF'S C O -C O UNSEL DEFENDANT DEFENDANT DEFENDANT DEFENDANT MIAMI, FL 33134 TAMPA, FL 33623 DOB City, State, Zip
BANKUNITED BANKUNITED FSB PASKEW ICZ, SER ENA KAY ESQ R O SE, ER IN M ESQ FR ANKLIN-PR ESCO TT, JENNIFER PR ESCO TT, W ALTER DO E, JO HN DO E, MAR Y
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA BANKUNITED, as [purported] successor in interest to [failed] BANKUNITED, FSB., Plaintiff, vs. JENNIFER FRANKLIN-PRESCOTT, et al., Defendants. ___________________________________________________________________/ MOTION TO CLARIFY ALLEGED “PLAINTIFF(S)”/”PARTIES” PUBLISHED NOTICE OF RECORD FRAUD ON THE COURT NOTICE OF SERVICE OF PLEADING(S) UPON ERIN M. ROSE QUINN CASE NO.: 09-6016-CA
MOTION TO CLARIFY ALLEGED PLAINTIFF(S) AND NOTICE OF FAILED BANK
“PLAINTIFF” BANK FAILED 1. “BANKUNITED, FSB” failed. FEDERAL SEIZURE 2. Federal regulators had seized the “Plaintiff” thrift. FAILED BANK FOUNDER AND TROUBLED ATTORNEY CAMNER 3. ALFRED CAMNER, troubled founder and attorney, has been in an acrimonious battle with the board of BANKUNITED Financial Corp., former parent company.
“PLAINTIFF’S” BANKRUPTCY 4. BANKUNITED Financial filed for protection under Chapter 11 of the Federal bankruptcy code, listing total assets of $37.7 million and total debts of $559.7 million. Here, shareholders were wiped out. BANKUNITED was sold to a group of private firms led by banker John Kanas. TRICKERY & DECEPTION 5. Bankrupt “BANKUNITED, FSB” appeared as “Plaintiff”. See Exhibit: Docket, Parties. 6. “Paskewicz, Serena Kay, Esq.” appeared as “Plaintiff’s Attorney”. Id. 7. Troubled law firm Camner Lipsitz was dismissed. Here, “Paskewicz” has no authority to represent failed “BANKUNITED, FSB”. FACIALLY NON-MERITORIOUS ACTION 8. Given the apparent recorded chaos, “loss”, “destruction”, and cancellation of any and all debt, the action was non-meritorious. UNKNOWN LOSS OR DESTRUCTION 9. Purported failed “Plaintiff” asserted that the time and manner of purported loss and destruction were “unknown”. Thereby, “Plaintiff” bankrupt bank failed to comply with Ch. 71, Florida Statutes. DISCHARGE OF ANY PRETENDED DEBT 10. If the holder of an instrument destroys it, he thereby forgives and discharges any debt. Here concededly, manner and time of destruction or loss were “unknown”. 11. The holder may not maintain an action based upon the purportedly destroyed instrument. Here, any pretended instrument was discharged by cancellation. See also District of Columbia v. Cornell, 130 US 655, 32 L ed 1041, 9 S Ct 694; State Street Trust Co.
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v Muskogee Electric Traction Co. (CA10 Okla) 204 F2d 920; 11 Am Jur 2d BILLS AND NOTES; § 913. CORRUPT INTENT 12. “Plaintiff” failed bank had corrupt intent to obtain illegal benefits to “avoid” failure and misrepresent assets. TROUBLED FOUNDER OF FAILED BANK WAS NOT “COUNSEL” 13. Troubled Alfred Camner, founder of bankrupt “BANKUNITED, FSB”, is not appearing for the purported Plaintiff. 14. The Docket entry dated “02/22/2010” fraudulently misrepresented: “Notice of Appearance as Co-Counsel by Erin M. Rose Quinn on behalf of Plaintiff”. Here, no other known “Counsel” appeared to represent the purported Plaintiff at that time. 15. In particular, Alfred Camner, and the Attorneys with troubled Camner Lipsitz under its founder Camner, are not representing the Plaintiff. Here, “Erin M. Rose Quinn’s” record misrepresentation appeared to be in bad faith and for deceptive purposes. While the troubled bank’s failure had been evident for a very long time, the failed bank’s founder Alfred Camner took improper and facially non-meritorious action against Jennifer Franklin Prescott. DECEPTION 16. Here, no authentic Promissory Note and/or Mortgage had ever existed. Therefore here admittedly, no such Note or Mortgage could have possibly been “in the custody or control of” the failed bank. Because troubled founder of the failed bank and Attorney Alfred Camner had a conflict of interest, Camner and Camner Lipsitz pleaded lack of any knowledge and control.
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17. No secondary or any other evidence existed, because failed bank founder Camner could not establish any “loss”. Troubled bank founder Camner did not know what he had “control of”, and therefore, the bank failed. FAILURE & IMPOSSIBILITY TO “REESTABLISH” PURPORTED PAPER FAILURE TO SET FORTH TIME AND MANNER OF FAKED “LOSS” 18. Violative of § 71.041(5), the purported Plaintiff failed to set forth: “the time and manner of loss or destruction”. FAILURE TO ATTACH “SUBSTANTIAL COPY” 19. Violative of § 71.041(5), the purported Plaintiff failed to attach: “a substantial copy of that lost or destroyed”, because admittedly, “the time and manner of loss or destruction” and that “lost or destroyed” were “unknown”. 20. Because the purported Plaintiff did not know “Counsel”, “that lost of destroyed”, and “the time and manner of loss or destruction”, the purported Plaintiff also failed to set forth and/or ascertain “that the persons named in the complaint are the only persons known to plaintiff who are interested for or against such reestablishment”. See § 71.041(5), Fla. Stat. NON-COMPLIANCE AND FAILURE TO REESTABLISH ANY PAPER 21. Therefore here, the purported Plaintiff failed to comply with Chapter 71, Fla. Stat., did not reestablish any paper, and could not possibly reestablish any paper. Thus, the allegations were absolutely non-meritorious, and the Complaint shall be dismissed.
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FAILED “BANKUNITED, FSB” ADMITTEDLY FABRICATED “MORTGAGE” 22. Bankrupt “BANKUNITED, FSB”, the purported “Plaintiff”, admitted the record absence of any interest and/or “promissory note” in its “custody or control”: “6. Said [non-existent] Promissory Note and Mortgage have been lost or destroyed and are not in the custody or control of BANKUNITED, and the time and manner of the loss or destruction is unknown.” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 3. FAILED BANK’S FAILURE TO SATISFY “REQUIRED CONDITIONS” 23. Bankrupt “BANKUNITED, FSB.”, a.k.a. “BANKUNITED, FSB”, and/or “BANKUNITED” failed to satisfy “conditions precedent to the institution of” this action. Id., p. 2. FAILED BANK’S FRAUDULENT PRETENSES ON THE RECORD 24. “Plaintiff” failed bank fraudulently pretended that the “conditions precedent to the institution of” this facially fraudulent action “occurred” and/or had “been performed or excused”. 25. Here, said bankrupt bank, Camner Lipsitz, and/or the dismissed firm’s founder Alfred Camner did not comply with the Fair Debt Collection Practices Act. LACK OF GOVERNMENT AND/OR JUDICIAL AUTHORITY TO FABRICATE ‘LOAN’ 26. Jennifer Franklin Prescott, who is a European citizen, holds unimpeachable title to her publicly recorded homestead in Naples, Florida, U.S.A. 27. For claims asserted in Federal Court against the presiding Judge, Jennifer Franklin Prescott (“Prescott”) does not submit to the jurisdiction. 28. Neither the Defendant presiding judge nor any judge had any official right or Government authority to fabricate, re-fabricate, and/or “re-establish” that which had never existed. Id. PUBLIC RECORD OF BANKRUPT “PLAINTIFF’S” FRAUDULENT HISTORY
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29. Purportedly on behalf of “Plaintiff” bankrupt bank “BANKUNITED, FSB”, and/or “BANKUNITED”, law firm Camner Lipsitz filed a prima facie fraudulent “complaint” against Prescott. RECORD DECEPTION, TRICKERY, FRAUD 30. Here, the purported “Plaintiff’s” designations were deceptive and for the unlawful purpose of misleading the public and property owners. 31. Here, purported “Plaintiff” “BANKUNITED, FSB” had failed. The bankrupt bank had been founded and mis-managed for most of its troubled history by Alfred Camner, the head of reportedly dismissed Camner Lipsitz. 32. A Federal shareholder class action lawsuit had targeted said Defendant Alfred Camner and other former players at the bankrupt bank, who had allegedly deceived investors about the quality of the bankrupt bank’s loan portfolio. 33. Here, Defendant Camner’s outfit did a “significant amount of work” for “Plaintiff” bankrupt “BANKUNITED, FSB”, while signs of the bankrupt bank’s failure had been evident for a very long time. 34. Private equity players “formed” another “BANKUNITED” to play with the assets of the failed bank, and Alfred Camner and Camner Lipsitz were reportedly dismissed pursuant to the record. The failed bank and the law firm have a dispute over legal fees pending in MiamiDade County Circuit Court. The bank reportedly posted a $3 million bond in that case. 35. Here, BANKUNITED itself could no longer have any confidence in troubled original founder Alfred Camner and his failing outfit Camner Lipitz and thus dismissed said judicial officers.
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36. Here after said dismissal of Camner Lipsitz, attorneys of said firm had no authority to appear and perpetrate fraud on this Court. FAILED BANK FAKED “INTEREST” 37. Here as a matter of law and public record, failed “BANKUNITED, FSB” has been defunct. In this case, no “mortgage” had ever been “in the custody or control of” bankrupt “BANKUNITED, FSB”. 38. Here, “BANKUNITED” could not possibly be any “successor in interest” and/or holder of any interest in Prescott’s record homestead, because bankrupt “BANKUNITED, FSB” had never acquired any interest of record. Here pursuant to the record, BANKUNITED, FSB went bankrupt, and no valid “mortgage” had existed. 39. Admittedly “the time and manner of the loss or destruction is unknown”, because no “mortgage” had ever existed, and the “Plaintiff” failed bank fabricated “loss” and/or “destruction”. Because no “mortgage” had ever been “in the custody” of bankrupt “BANKUNITED, FSB”, the sham “action” is facially frivolous and fraudulent. 40. Here, the failed “Plaintiff’s” fabricated “interest”, “promissory note”, and/or “mortgage” had never existed. The Plaintiff bank and founder’s law firm fraudulently concealed “manner and time” of the fabrication of the failed bank’s and/or law firm’s fictitious “promissory note”. BANKRUPT BANK FABRICATED “DAMAGES” 41. Here, the “Plaintiff” bankrupt bank fabricated “damages that exceed $15,000.00 …” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 2. PRIMA FACIE FRIVOLOUS & FRAUDULENT “CLAIM” 42. Here, the bankrupt “Plaintiff” and/or court could not possibly “reestablish” and/or (re-) fabricate that which admittedly had never existed.
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DEFUNCT BANKUNITED, FSB., PERPETRATED FRAUD ON THIS COURT 43. Here, defunct bank “BANKUNITED, FSB.” perpetrated fraud upon this court and acted in bad faith. The “Plaintiff” bankrupt bank is liable for damages and expenses. BANKRUPT BANK’S TRICKERY & DECEPTION - EXHIBITS 44. Here therefore, the bankrupt bank’s “Exhibit(s)” of a non-existent and purportedly “lost” and/or destroyed “mortgage” were deceptive. 45. Here, there was no evidence to support any “lis pendens”. 46. Here admittedly, no valid evidence of any interest in the name of the bankrupt bank could have possibly existed, and the failed “Plaintiff” bank perpetrated prima facie fraud on the record. WHEREFORE, Jennifer Franklin Prescott demands 1. An Order clarifying “Plaintiff” in this prima facie non-meritorious action: 2. An Order declaring that Camner Lipsitz and/or its Attorneys are not any Counsel” 3. An Order clarifying Counsel for failed Bank and purported Plaintiff; 4. An Order enjoining said deceptive misrepresentation of Plaintiff’s counsel; 5. An Order clarifying who is truly representing failed “BANKUNITED”; 6. An Order dismissing the purported “action” as facially fraudulent and frivolous; 7. An Order dismissing this facially fraudulent action, because a non-existent “instrument” cannot possibly be “reestablished”, “re-faked”, and/or (re-)fabricated as a matter of law; 8. An Order dismissing this facially fraudulent action, because “Plaintiff” bankrupt bank never was “in the custody or control” of any valid “mortgage” before the bank failed and defrauded property owners and/or investors on the record;
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9. An Order for sanctions and expenses against “Plaintiff” bankrupt bank “BANKUNITED, FSB” and its dismissed and/or fired attorneys at Camner Lipsitz; 10. An order removing the fired judicial officers with the Camner Lipsitz firm from these proceedings, and striking their fraudulent pleadings, because they perpetrated said record fraud and fraud on this Court and in particular, fraudulently pretended a lost and/or destroyed “mortgage”. ________________________ /s/Jennifer Franklin Prescott Victim of bankrupt BANKUNITED, FSB’s record fraud and fraud on this Court Victim of failed BANKUNITED founder Alfred Camner’s record fraud & fraud on this Court EXHIBIT: Docket; publicly recorded “parties”
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FAILURE TO SET FORTH TIME AND MANNER OF FAKED “LOSS” 1. Violative of § 71.041(5), the purported Plaintiff failed to set forth: “the time and manner of loss or destruction”. FAILURE TO ATTACH “SUBSTANTIAL COPY” 2. Violative of § 71.041(5), the purported Plaintiff failed to attach: “a substantial copy of that lost or destroyed”, because admittedly, “the time and manner of loss or destruction” and that “lost or destroyed” were “unknown”. 3. Because the purported Plaintiff did not know “Counsel”, “that lost of destroyed”, and “the time and manner of loss or destruction”, the purported Plaintiff also failed to set forth and/or ascertain
“that the persons named in the complaint are the only persons known to plaintiff who are interested for or against such reestablishment”. See § 71.041(5), Fla. Stat. NON-COMPLIANCE AND FAILURE TO REESTABLISH ANY PAPER 4. Therefore here, the purported Plaintiff failed to comply with Chapter 71, Fla. Stat., did not reestablish any paper, and could not possibly reestablish any paper. Thus, the allegations were absolutely non-meritorious, and the Complaint shall be dismissed. TROUBLED FOUNDER OF FAILED BANK WAS NOT “COUNSEL” 5. Troubled Alfred Camner, founder of bankrupt “BANKUNITED, FSB”, is not appearing for the purported Plaintiff. 6. The Docket entry dated “02/22/2010” fraudulently misrepresented: “Notice of Appearance as Co-Counsel by Erin M. Rose Quinn on behalf of Plaintiff”. Here, no other known “Counsel” appeared to represent the purported Plaintiff at that time. 7. In particular, Alfred Camner, and the Attorneys with troubled Camner Lipsitz under its founder Camner, are not representing the Plaintiff. Here, “Erin M. Rose Quinn’s” record misrepresentation appeared to be in bad faith and for deceptive purposes. While the troubled bank’s failure had been evident for a very long time, the failed bank’s founder Alfred Camner took improper and facially non-meritorious action against Jennifer Franklin Prescott. DECEPTION 8. Here, no authentic Promissory Note and/or Mortgage had ever existed. Therefore here admittedly, no such Note or Mortgage could have possibly been “in the custody or control of” the failed bank. Because troubled founder of the failed bank and Attorney Alfred
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Camner had a conflict of interest, Camner and Camner Lipsitz pleaded lack of any knowledge and control. 9. No secondary or any other evidence existed, because failed bank founder Camner could not establish any “loss”. Troubled bank founder Camner did not know what he had “control of”, and therefore, the bank failed. FAILED “BANKUNITED, FSB” ADMITTEDLY FABRICATED “MORTGAGE” 10. Bankrupt “BANKUNITED, FSB”, the purported “Plaintiff”, admitted the record absence of any interest and/or “promissory note” in its “custody or control”: “6. Said [non-existent] Promissory Note and Mortgage have been lost or destroyed and are not in the custody or control of BANKUNITED, and the time and manner of the loss or destruction is unknown.” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 3. FAILED BANK’S FAILURE TO SATISFY “REQUIRED CONDITIONS” 11. Bankrupt “BANKUNITED, FSB.”, a.k.a. “BANKUNITED, FSB”, and/or “BANKUNITED” failed to satisfy “conditions precedent to the institution of” this action. Id., p. 2. FAILED BANK’S FRAUDULENT PRETENSES ON THE RECORD 12. “Plaintiff” failed bank fraudulently pretended that the “conditions precedent to the institution of” this facially fraudulent action “occurred” and/or had “been performed or excused”. 13. Here, said bankrupt bank, Camner Lipsitz, and/or the dismissed firm’s founder Alfred Camner did not comply with the Fair Debt Collection Practices Act. LACK OF GOVERNMENT AND/OR JUDICIAL AUTHORITY TO FABRICATE ‘LOAN’ 14. Jennifer Franklin Prescott, who is a European citizen, holds unimpeachable title to her publicly recorded homestead in Naples, Florida, U.S.A.
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15. For claims asserted in Federal Court against the presiding Judge, Jennifer Franklin Prescott (“Prescott”) does not submit to the jurisdiction. 16. Neither the Defendant presiding judge nor any judge had any official right or Government authority to fabricate, re-fabricate, and/or “re-establish” that which had never existed. Id. PUBLIC RECORD OF BANKRUPT “PLAINTIFF’S” FRAUDULENT HISTORY 17. Purportedly on behalf of “Plaintiff” bankrupt bank “BANKUNITED, FSB”, and/or “BANKUNITED”, law firm Camner Lipsitz filed a prima facie fraudulent “complaint” against Prescott. RECORD DECEPTION, TRICKERY, FRAUD 18. Here, the purported “Plaintiff’s” designations were deceptive and for the unlawful purpose of misleading the public and property owners. 19. Here, purported “Plaintiff” “BANKUNITED, FSB” had failed. The bankrupt bank had been founded and mis-managed for most of its troubled history by Alfred Camner, the head of reportedly dismissed Camner Lipsitz. 20. A Federal shareholder class action lawsuit had targeted said Defendant Alfred Camner and other former players at the bankrupt bank, who had allegedly deceived investors about the quality of the bankrupt bank’s loan portfolio. 21. Here, Defendant Camner’s outfit did a “significant amount of work” for “Plaintiff” bankrupt “BANKUNITED, FSB”, while signs of the bankrupt bank’s failure had been evident for a very long time. 22. Private equity players “formed” another “BANKUNITED” to play with the assets of the failed bank, and Alfred Camner and Camner Lipsitz were reportedly dismissed pursuant to
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the record. The failed bank and the law firm have a dispute over legal fees pending in MiamiDade County Circuit Court. The bank reportedly posted a $3 million bond in that case. 23. Here, BANKUNITED itself could no longer have any confidence in troubled original founder Alfred Camner and his failing outfit Camner Lipitz and thus dismissed said judicial officers. 24. Here after said dismissal of Camner Lipsitz, attorneys of said firm had no authority to appear and perpetrate fraud on this Court. FAILED BANK FAKED “INTEREST” 25. Here as a matter of law and public record, failed “BANKUNITED, FSB” has been defunct. In this case, no “mortgage” had ever been “in the custody or control of” bankrupt “BANKUNITED, FSB”. 26. Here, “BANKUNITED” could not possibly be any “successor in interest” and/or holder of any interest in Prescott’s record homestead, because bankrupt “BANKUNITED, FSB” had never acquired any interest of record. Here pursuant to the record, BANKUNITED, FSB went bankrupt, and no valid “mortgage” had existed. 27. Admittedly “the time and manner of the loss or destruction is unknown”, because no “mortgage” had ever existed, and the “Plaintiff” failed bank fabricated “loss” and/or “destruction”. Because no “mortgage” had ever been “in the custody” of bankrupt “BANKUNITED, FSB”, the sham “action” is facially frivolous and fraudulent. 28. Here, the failed “Plaintiff’s” fabricated “interest”, “promissory note”, and/or “mortgage” had never existed. The Plaintiff bank and founder’s law firm fraudulently concealed “manner and time” of the fabrication of the failed bank’s and/or law firm’s fictitious “promissory note”. BANKRUPT BANK FABRICATED “DAMAGES”
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29. Here, the “Plaintiff” bankrupt bank fabricated “damages that exceed $15,000.00 …” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 2. PRIMA FACIE FRIVOLOUS & FRAUDULENT “CLAIM” 30. Here, the bankrupt “Plaintiff” and/or court could not possibly “reestablish” and/or (re-) fabricate that which admittedly had never existed. DEFUNCT BANKUNITED, FSB., PERPETRATED FRAUD ON THIS COURT 31. Here, defunct bank “BANKUNITED, FSB.” perpetrated fraud upon this court and acted in bad faith. The “Plaintiff” bankrupt bank is liable for damages and expenses. BANKRUPT BANK’S TRICKERY & DECEPTION - EXHIBITS 32. Here therefore, the bankrupt bank’s “Exhibit(s)” of a non-existent and purportedly “lost” and/or destroyed “mortgage” were deceptive. 33. Here, there was no evidence to support any “lis pendens”. 34. Here admittedly, no valid evidence of any interest in the name of the bankrupt bank could have possibly existed, and the failed “Plaintiff” bank perpetrated prima facie fraud on the record. WHEREFORE, Jennifer Franklin Prescott demands 1. An Order dismissing the Complaint for impossibility to reestablish a non-existent purported paper; 2. An Order enjoining said deceptive misrepresentation of Plaintiff’s counsel; 3. An Order clarifying who is truly representing failed “BANKUNITED”; 4. An Order dismissing the purported “action” as facially fraudulent and frivolous; 5. An Order dismissing this facially fraudulent action, because a non-existent “instrument” cannot possibly be “reestablished”, “re-faked”, and/or (re-)fabricated as a matter of law;
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6. An Order dismissing this facially fraudulent action, because “Plaintiff” bankrupt bank never was “in the custody or control” of any valid “mortgage” before the bank failed and defrauded property owners and/or investors on the record; 7. An Order for sanctions and expenses against “Plaintiff” bankrupt bank “BANKUNITED, FSB” and its dismissed and/or fired attorneys at Camner Lipsitz; 8. An order removing the fired judicial officers with the Camner Lipsitz firm from these proceedings, and striking their fraudulent pleadings, because they perpetrated said record fraud and fraud on this Court and in particular, fraudulently pretended a lost and/or destroyed “mortgage”. ________________________ /s/Jennifer Franklin Prescott Victim of bankrupt BANKUNITED, FSB’s record fraud and fraud on this Court Victim of failed BANKUNITED founder Alfred Camner’s record fraud & fraud on this Court EXHIBIT: Docket
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7/23/2010
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Style: BANKUNITED vs FR ANKLIN-PR ESC O TT, JENNIFER Uniform Case Number: 112009C A0060160001XX Clerks Case Number: 0906016C A Court Type: CIRCUIT C IVIL Case Type: MO R TGAGE FO R ECLO SUR ES Judge: HAYES, HUGH D Case Status: O PEN Next Court Date: Last Docket Date: 07/09/2010 Disposition Judge: Disposed: Reopen Reason: Reopened: Reopen Close: A ppealed: Filed: 07/09/2009
Parties Name
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Financials Type PLAINTIFF PLAINTIFF PLAINTIFF'S ATTO R NEY PLAINTIFF'S C O -C O UNSEL DEFENDANT DEFENDANT DEFENDANT DEFENDANT MIAMI, FL 33134 TAMPA, FL 33623 DOB City, State, Zip
BANKUNITED BANKUNITED FSB PASKEW ICZ, SER ENA KAY ESQ R O SE, ER IN M ESQ FR ANKLIN-PR ESCO TT, JENNIFER PR ESCO TT, W ALTER DO E, JO HN DO E, MAR Y
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA BANKUNITED, as [purported] successor in interest to [failed] BANKUNITED, FSB., Plaintiff, vs. JENNIFER FRANKLIN-PRESCOTT, et al., Defendants. ___________________________________________________________________/ MOTION TO CLARIFY ALLEGED “PLAINTIFF(S)”/”PARTIES” PUBLISHED NOTICE OF RECORD FRAUD ON THE COURT NOTICE OF SERVICE OF PLEADING(S) UPON ERIN M. ROSE QUINN CASE NO.: 09-6016-CA
MOTION TO CLARIFY ALLEGED PLAINTIFF(S) AND NOTICE OF FAILED BANK
“PLAINTIFF” BANK FAILED 1. “BANKUNITED, FSB” failed. FEDERAL SEIZURE 2. Federal regulators had seized the “Plaintiff” thrift. FAILED BANK FOUNDER AND TROUBLED ATTORNEY CAMNER 3. ALFRED CAMNER, troubled founder and attorney, has been in an acrimonious battle with the board of BANKUNITED Financial Corp., former parent company.
“PLAINTIFF’S” BANKRUPTCY 4. BANKUNITED Financial filed for protection under Chapter 11 of the Federal bankruptcy code, listing total assets of $37.7 million and total debts of $559.7 million. Here, shareholders were wiped out. BANKUNITED was sold to a group of private firms led by banker John Kanas. TRICKERY & DECEPTION 5. Bankrupt “BANKUNITED, FSB” appeared as “Plaintiff”. See Exhibit: Docket, Parties. 6. “Paskewicz, Serena Kay, Esq.” appeared as “Plaintiff’s Attorney”. Id. 7. Troubled law firm Camner Lipsitz was dismissed. Here, “Paskewicz” has no authority to represent failed “BANKUNITED, FSB”. FACIALLY NON-MERITORIOUS ACTION 8. Given the apparent recorded chaos, “loss”, “destruction”, and cancellation of any and all debt, the action was non-meritorious. UNKNOWN LOSS OR DESTRUCTION 9. Purported failed “Plaintiff” asserted that the time and manner of purported loss and destruction were “unknown”. Thereby, “Plaintiff” bankrupt bank failed to comply with Ch. 71, Florida Statutes. DISCHARGE OF ANY PRETENDED DEBT 10. If the holder of an instrument destroys it, he thereby forgives and discharges any debt. Here concededly, manner and time of destruction or loss were “unknown”. 11. The holder may not maintain an action based upon the purportedly destroyed instrument. Here, any pretended instrument was discharged by cancellation. See also District of Columbia v. Cornell, 130 US 655, 32 L ed 1041, 9 S Ct 694; State Street Trust Co.
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v Muskogee Electric Traction Co. (CA10 Okla) 204 F2d 920; 11 Am Jur 2d BILLS AND NOTES; § 913. CORRUPT INTENT 12. “Plaintiff” failed bank had corrupt intent to obtain illegal benefits to “avoid” failure and misrepresent assets. TROUBLED FOUNDER OF FAILED BANK WAS NOT “COUNSEL” 13. Troubled Alfred Camner, founder of bankrupt “BANKUNITED, FSB”, is not appearing for the purported Plaintiff. 14. The Docket entry dated “02/22/2010” fraudulently misrepresented: “Notice of Appearance as Co-Counsel by Erin M. Rose Quinn on behalf of Plaintiff”. Here, no other known “Counsel” appeared to represent the purported Plaintiff at that time. 15. In particular, Alfred Camner, and the Attorneys with troubled Camner Lipsitz under its founder Camner, are not representing the Plaintiff. Here, “Erin M. Rose Quinn’s” record misrepresentation appeared to be in bad faith and for deceptive purposes. While the troubled bank’s failure had been evident for a very long time, the failed bank’s founder Alfred Camner took improper and facially non-meritorious action against Jennifer Franklin Prescott. DECEPTION 16. Here, no authentic Promissory Note and/or Mortgage had ever existed. Therefore here admittedly, no such Note or Mortgage could have possibly been “in the custody or control of” the failed bank. Because troubled founder of the failed bank and Attorney Alfred Camner had a conflict of interest, Camner and Camner Lipsitz pleaded lack of any knowledge and control.
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17. No secondary or any other evidence existed, because failed bank founder Camner could not establish any “loss”. Troubled bank founder Camner did not know what he had “control of”, and therefore, the bank failed. FAILURE & IMPOSSIBILITY TO “REESTABLISH” PURPORTED PAPER FAILURE TO SET FORTH TIME AND MANNER OF FAKED “LOSS” 18. Violative of § 71.041(5), the purported Plaintiff failed to set forth: “the time and manner of loss or destruction”. FAILURE TO ATTACH “SUBSTANTIAL COPY” 19. Violative of § 71.041(5), the purported Plaintiff failed to attach: “a substantial copy of that lost or destroyed”, because admittedly, “the time and manner of loss or destruction” and that “lost or destroyed” were “unknown”. 20. Because the purported Plaintiff did not know “Counsel”, “that lost of destroyed”, and “the time and manner of loss or destruction”, the purported Plaintiff also failed to set forth and/or ascertain “that the persons named in the complaint are the only persons known to plaintiff who are interested for or against such reestablishment”. See § 71.041(5), Fla. Stat. NON-COMPLIANCE AND FAILURE TO REESTABLISH ANY PAPER 21. Therefore here, the purported Plaintiff failed to comply with Chapter 71, Fla. Stat., did not reestablish any paper, and could not possibly reestablish any paper. Thus, the allegations were absolutely non-meritorious, and the Complaint shall be dismissed.
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FAILED “BANKUNITED, FSB” ADMITTEDLY FABRICATED “MORTGAGE” 22. Bankrupt “BANKUNITED, FSB”, the purported “Plaintiff”, admitted the record absence of any interest and/or “promissory note” in its “custody or control”: “6. Said [non-existent] Promissory Note and Mortgage have been lost or destroyed and are not in the custody or control of BANKUNITED, and the time and manner of the loss or destruction is unknown.” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 3. FAILED BANK’S FAILURE TO SATISFY “REQUIRED CONDITIONS” 23. Bankrupt “BANKUNITED, FSB.”, a.k.a. “BANKUNITED, FSB”, and/or “BANKUNITED” failed to satisfy “conditions precedent to the institution of” this action. Id., p. 2. FAILED BANK’S FRAUDULENT PRETENSES ON THE RECORD 24. “Plaintiff” failed bank fraudulently pretended that the “conditions precedent to the institution of” this facially fraudulent action “occurred” and/or had “been performed or excused”. 25. Here, said bankrupt bank, Camner Lipsitz, and/or the dismissed firm’s founder Alfred Camner did not comply with the Fair Debt Collection Practices Act. LACK OF GOVERNMENT AND/OR JUDICIAL AUTHORITY TO FABRICATE ‘LOAN’ 26. Jennifer Franklin Prescott, who is a European citizen, holds unimpeachable title to her publicly recorded homestead in Naples, Florida, U.S.A. 27. For claims asserted in Federal Court against the presiding Judge, Jennifer Franklin Prescott (“Prescott”) does not submit to the jurisdiction. 28. Neither the Defendant presiding judge nor any judge had any official right or Government authority to fabricate, re-fabricate, and/or “re-establish” that which had never existed. Id. PUBLIC RECORD OF BANKRUPT “PLAINTIFF’S” FRAUDULENT HISTORY
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29. Purportedly on behalf of “Plaintiff” bankrupt bank “BANKUNITED, FSB”, and/or “BANKUNITED”, law firm Camner Lipsitz filed a prima facie fraudulent “complaint” against Prescott. RECORD DECEPTION, TRICKERY, FRAUD 30. Here, the purported “Plaintiff’s” designations were deceptive and for the unlawful purpose of misleading the public and property owners. 31. Here, purported “Plaintiff” “BANKUNITED, FSB” had failed. The bankrupt bank had been founded and mis-managed for most of its troubled history by Alfred Camner, the head of reportedly dismissed Camner Lipsitz. 32. A Federal shareholder class action lawsuit had targeted said Defendant Alfred Camner and other former players at the bankrupt bank, who had allegedly deceived investors about the quality of the bankrupt bank’s loan portfolio. 33. Here, Defendant Camner’s outfit did a “significant amount of work” for “Plaintiff” bankrupt “BANKUNITED, FSB”, while signs of the bankrupt bank’s failure had been evident for a very long time. 34. Private equity players “formed” another “BANKUNITED” to play with the assets of the failed bank, and Alfred Camner and Camner Lipsitz were reportedly dismissed pursuant to the record. The failed bank and the law firm have a dispute over legal fees pending in MiamiDade County Circuit Court. The bank reportedly posted a $3 million bond in that case. 35. Here, BANKUNITED itself could no longer have any confidence in troubled original founder Alfred Camner and his failing outfit Camner Lipitz and thus dismissed said judicial officers.
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36. Here after said dismissal of Camner Lipsitz, attorneys of said firm had no authority to appear and perpetrate fraud on this Court. FAILED BANK FAKED “INTEREST” 37. Here as a matter of law and public record, failed “BANKUNITED, FSB” has been defunct. In this case, no “mortgage” had ever been “in the custody or control of” bankrupt “BANKUNITED, FSB”. 38. Here, “BANKUNITED” could not possibly be any “successor in interest” and/or holder of any interest in Prescott’s record homestead, because bankrupt “BANKUNITED, FSB” had never acquired any interest of record. Here pursuant to the record, BANKUNITED, FSB went bankrupt, and no valid “mortgage” had existed. 39. Admittedly “the time and manner of the loss or destruction is unknown”, because no “mortgage” had ever existed, and the “Plaintiff” failed bank fabricated “loss” and/or “destruction”. Because no “mortgage” had ever been “in the custody” of bankrupt “BANKUNITED, FSB”, the sham “action” is facially frivolous and fraudulent. 40. Here, the failed “Plaintiff’s” fabricated “interest”, “promissory note”, and/or “mortgage” had never existed. The Plaintiff bank and founder’s law firm fraudulently concealed “manner and time” of the fabrication of the failed bank’s and/or law firm’s fictitious “promissory note”. BANKRUPT BANK FABRICATED “DAMAGES” 41. Here, the “Plaintiff” bankrupt bank fabricated “damages that exceed $15,000.00 …” See facially fraudulent “complaint” by defunct “BANKUNITED, FSB”, p. 2. PRIMA FACIE FRIVOLOUS & FRAUDULENT “CLAIM” 42. Here, the bankrupt “Plaintiff” and/or court could not possibly “reestablish” and/or (re-) fabricate that which admittedly had never existed.
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DEFUNCT BANKUNITED, FSB., PERPETRATED FRAUD ON THIS COURT 43. Here, defunct bank “BANKUNITED, FSB.” perpetrated fraud upon this court and acted in bad faith. The “Plaintiff” bankrupt bank is liable for damages and expenses. BANKRUPT BANK’S TRICKERY & DECEPTION - EXHIBITS 44. Here therefore, the bankrupt bank’s “Exhibit(s)” of a non-existent and purportedly “lost” and/or destroyed “mortgage” were deceptive. 45. Here, there was no evidence to support any “lis pendens”. 46. Here admittedly, no valid evidence of any interest in the name of the bankrupt bank could have possibly existed, and the failed “Plaintiff” bank perpetrated prima facie fraud on the record. WHEREFORE, Jennifer Franklin Prescott demands 1. An Order clarifying “Plaintiff” in this prima facie non-meritorious action: 2. An Order declaring that Camner Lipsitz and/or its Attorneys are not any Counsel” 3. An Order clarifying Counsel for failed Bank and purported Plaintiff; 4. An Order enjoining said deceptive misrepresentation of Plaintiff’s counsel; 5. An Order clarifying who is truly representing failed “BANKUNITED”; 6. An Order dismissing the purported “action” as facially fraudulent and frivolous; 7. An Order dismissing this facially fraudulent action, because a non-existent “instrument” cannot possibly be “reestablished”, “re-faked”, and/or (re-)fabricated as a matter of law; 8. An Order dismissing this facially fraudulent action, because “Plaintiff” bankrupt bank never was “in the custody or control” of any valid “mortgage” before the bank failed and defrauded property owners and/or investors on the record;
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9. An Order for sanctions and expenses against “Plaintiff” bankrupt bank “BANKUNITED, FSB” and its dismissed and/or fired attorneys at Camner Lipsitz; 10. An order removing the fired judicial officers with the Camner Lipsitz firm from these proceedings, and striking their fraudulent pleadings, because they perpetrated said record fraud and fraud on this Court and in particular, fraudulently pretended a lost and/or destroyed “mortgage”. ________________________ /s/Jennifer Franklin Prescott Victim of bankrupt BANKUNITED, FSB’s record fraud and fraud on this Court Victim of failed BANKUNITED founder Alfred Camner’s record fraud & fraud on this Court EXHIBIT: Docket; publicly recorded “parties”
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