COMPLAINT

Under the Illinois Rule of Evidence Rule No.1006. This is an action against JPMORGAN CHASE .Fidelity national finance owning Chase title insurance, as well as my title insurance, being a conflict of interest.

Insurance Fraud, not covering claims of covered accidents. Fraudulent Initiation of homeowner Insurance by Assurant, a company connected with Chase, for $3500/month Insurance Fraud, not covering claims of covered accidents. Bought by me at closing 7/31/2007., FNF, who owns my title insurance homeowner policy, denying claim to pay. Bank NATIONAL Association for Declaratory Judgment under the Illinois Rule of Evidence Rule No. 1006, breach of contract, fraudulent misrepresentation, violation of the Illinois Consignment of Art Act, and related claims arising from a business relationship. Chrystyan v. Feinberg, 156 Ill.App.3d 781, 109 Ill.Dec. 412, 510 N.E.2d 33 (1987).

Forgery

Handwriting samples from Susan and Ricky Williams were given by Chase, in their fraud investigation. Police report was filed in Hickory Hills, IL an well as Chase doing an investigation.(EXHIBIT 8 AND 9)

Predatory loan initiation, of 2 minorities, both not working, and me on disability making it hard to work. OWEN LOAN SERVICING, LLC. Plaintiff-Appellant v IRMA VILLATE, Defendant-Appellee No. 1-13-1528 APPELLATE COURT OF ILLINOIS FIRST DISTRICT FOURTH DIVISION July 31,2014. Fraud in a contract voids the contract. See: Middlesex Mut. Assurance Co. v. Walsh, 590 A.2d 957, 963-964, 218 Conn. 681, 691-692 (1991). Fraud includes forgery.

For: Fraud, breach of contract, predatory loan, forced insurance. Insurance fraud,

By: Susan F. Williams

COMPLAINT FOR DECLARATORY JUDGMENT AND PERMANENT INJUNCTION

The violation is the 1st forbearance agreement for 3 payments was not in writing. After the agreed upon 3 payments were made, the bank said to continue making those payments every month, at $930/month.. After almost 7 months a written forbearance agreement was sent by CHASE for 3 payments of $1028.48 /month( EXHIBIT 11) These were paid and at the end, we were told to keep

making payments every month. This went on for a year. The last payment we sent was returned and we were told Chase refused a modification. All the information Chase asked for on my disability income and my monthly expenses were given to Chase, including the divorce of Susan and Ricky Williams. The forbearance Chase offered was $1700/month for 3 months. They would not let a counter or negotiation take place. The executive branch hung up on me, not willing to explain what the process was of doing a forbearance.

ALLEGATIONS

I .CHASE is engaged in systemic fraud upon the Bankruptcy Courts and other bankruptcy players for financial gain. CHASE etal refuses to offer the actual evidence of the transfers

Due to costs associated with providing standing of the true "chain of title." In FNF’s summary Judgement, it was suggested that Susan Williams files bankruptcy. CHASE and agents frequently

Lack evidence of the multiple transfers required to establish legitimate standing in bankruptcy particularly in the case Of W AMU originated Notes.

2. That CHASE has violated federal perjury statute 18 USC 1621.

3. Plaintiff believes and alleges that CHASE is "engaged in the business practice of deceiving" bankruptcy judges, Chapters 7, I l, and 13 Trustees, the Offices of the United States

Trustee, creditors, creditor attorneys, debtors in possession, debtors, and debtors attorneys as to CHASE's "status as a secured creditor in tens of thousands of bankruptcy cases filed nationwide."

4. Bakenie further alleges that through the use Of fabricated assignments, endorsements and affidavits that purport to transfer Deeds of Trust, Notes, and rights to all monies due under the terms of tens of thousands of non- negotiable promissory notes that CHASE has demonstrated a pattern and practice of playing "hide-and-seek" with debtors, judges and other bankruptcy players.

5. CHASE intentionally conceals the identity of the true parties in interest to enforce the terms of tens of thousands of residential non-negotiable promissory notes for its own financial benefit To the detriment of the integrity of the bankruptcy system.

6. CHASE services tens of thousands of residential home loans, many of which are pledged to Mortgage Backed Security Trusts.

7. CHASE allegedly acquired the assets o f WASHINGTON MUTUAL BANK NA (WAMU) from the FDIC after WA MU failed and was placed in receivership.

8. CHASE network attorneys file proofs of claims and Motions for Relief from Automatic Stay and falsely claim to be the party entitled to the monies due under the terms of the Notes

9. That the PSA (Pooling and Servicing Agreement of each private Mortgage Backed Trust serviced by CHASE contemplates no less than THREE true sales of each MLN from originator to sponsor

To depositor and finally to the Trustee of the MBS (the "Chain of Title").

10. CHASE and agents frequently lack evidence of the multiple transfers required to establish legitimate standing in bankruptcy, particularly in the case Of W AMU originated Notes.

11. Rather than prove up its own standing or the standing of the MBST, CHASE systematically misrepresents CHASE or a designated MB.ST to be a creditor in vast numbers of bankruptcy cases by utilizing manufactured documents. That CHASE et al "fabricated evidence is 'photo-shopped' and is PERSUASIVE and authentic in appearance so as to ensure legal victory in bankruptcy courts for unjust enrichment.

Tila: Under the Illinois Rule of Evidence Rule No. 1006 -this is an action against JPMORGAN CHASE, FISHER AND SHAPIRO, and Fidelity National Finance owning Chase's title insurance bought by me at closing 7/31/2007., FNF who owns my title insurance homeowner policy, denying claim to pay. JPMorgan CHASE, NATIONAL Association for breach of contract, fraudulent misrepresentation, violation of the Illinois Consignment of Art Act, and related claims arising from a business relationship. Another court referred to Chrystyan in Grot V. First Bank of Shaunburg to differentiate the facts, but it would Appear that it is beneficial as the court agreed and affirmed the ruling in Chrystyan. Chrystyan v. Feinberg, 510 NE 2d 33 - Ill: Appellate Court, 1st Dist. 1987

The debt buying on WAMU by Chase, while WAMU was in receivership. The debt buying of Pioneer Title Insurance by FNF Insurance, is a break in the chain of custody of title.

Ruination of credit, which has Ricky unsuccessful as well as me (pharmacist) for the negative connotations that invokes.

Respa violations (insurance claims are always refused, TILA was not given to buyers 24 hours in advance.) The loan closed 7/31/2007, NOT 7/30/20907. A motion to supply evidence will show the Notary, Ms. Gunty, Traveled on the toll road from Lombard to Hickory Hills on the 31 st, not the 30th.

The Defendant argued successfully in vacating the foreclosure and sale, the signature was forged and as such it never created any legal security interest in the house because

Of the fraud. He needs to look at the loan itself and ague what is in the mortgage document nothing else, so the signature is forged the loan is predatory, per the law and the mortgage agreement.

Unlawful Enrichment was said by CHASE or FNF.

Even if there was no contract, if they can prove that you used the card and didn't pay, then they can

Claim you were unjustly enriched. This is based upon the assumption that even without a binding, enforceable contract, you still knew there was an expectation that you would

Pay them, and they relied upon that expectation. I had tried to pay the loan, but CHASE kept refusing until Ricky Williams signed the contract, which he never did... As the continued attempt of CHASE to foreclose on my house, forged documents, and threatening me, I began to learn the laws that showed the loan was invalid.

Quasi contract: was a document the title company, Clarissa Gunty, tried to get me to sign (EXHIBIT 10)

Court's determination of an obligation of one party to another where no actual contract exists. It is based on the parties' conduct, mutual relationship, and/or on the possibility that one would be unjustly enriched at the expense of the other. In strict legal terms a quasi-contract does not constitute a formal contract, but is a legal remedy that allows a plaintiff to recover an award or benefit conferred on the defendant.

Under the Illinois Rule of Evidence Rule No. 1006 -this is an action against JPMORGAN CHASE, FISHER AND SHAPIRO, Fidelity National Finance owning Chase's title insurance bought by me at closing 7/31/2007.,

FNF who owns my title insurance homeowner policy, denying claim to pay. JPMorgan CHASE, NATIONAL Association for breach of contract, fraudulent misrepresentation, violation of the Illinois Consignment of Art Act, and related claims arising from a business relationship

I, Susan Williams, pray for discovery to ensure due process. Many facts are not being presented, as well as witnesses, documented phone calls, and correspondences with CHASE and the title insurance company, FNF.

(We) do hereby certify that a copy of this instrument was served upon all parties who have appeared and have not previously been found by the Court to be in default for failure to plead.

Date: Sept 30,2015

Susan F. Williams Prosee 99500

8830 S. 83RD CT.

HICKORY HILLS, IL 60457

lizzywingo@gmail.com

708-289-0383

COMPLAINT

Under the Illinois Rule of Evidence Rule No.1006

This is an action against JPMORGAN CHASE .Fidelity national finance owning Chase title insurance

Bought by me at closing 7/31/2007., FISHER AND SHAPIRO, who owns my title insurance

Homeowner policy, denying claim to pay. Bank NATIONAL Association for Declaratory Judgment

Under the Illinois Rule of Evidence Rule No. 1006, breach of contract, fraudulent misrepresentation,

Violation of the Illinois Consignment of Art Act, and related claims arising from a business relationship.

Chrystyan v. Feinberg, 156 Ill.App.3d 781, 109 Ill.Dec. 412, 510 N.E.2d 33 (1987).

http://www.justanswer.com/real-estate-law/92hk6-chrystyan-v-feinberg-156-ill-app-3d-781-109-ill-dec-412.html#ixzz3aFikHFHh

ra in response to the plaintiffs summary judgment a defendant cannot a party cannot defend against a moment we did in his complaint that an hour the bad Homburg 228 ILL died that greedy the 780, 786 a sense this is to rule and there are was known even ended at the time this motion was filed the Atty. for the defendant would you rule and why isn't waiting for the court date and on that court date I was unaware they use admitted any motions or answers. After looking at the ensues estimated by the defendants former Atty. Many of the answers were natural and it looked like a fed cut and paste document bill V Atty. Representing the defendant is a licensed Atty. in Illinois on charges were filed by the defendant for malpractice because they key function of a defendant's Atty. Is to represent them here it is known representation of the defendant in a reform the ruling in favor of the plaintiff or the summary judgment needs two being revisited the defendant also was accused by the plaintiff of not having evidence to support anything written on every time Olshan. The Atty. representing the defendant did not prevent any evidence of which there was many a running IE pray for an evidentiary hearing to show that equitable Lien on the property just a 14 to-