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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TENNESSEE

AT KNOXVILLE

LNV CORPORATION, )

)

Plaintiff, )

)

v. ) No.: 3:12-CV-468-TAV-HBG

)

CATHERINE GEBHARDT )

)

Defendant. )

CAMMY DEPEWS MOTION TO INTERVENE

Cammy Depew moves this Court for leave to intervene in this action as of right, pursuant

to Federal Rule of Civil Procedure 24(a)(2) or, alternatively, in permissive intervention pursuant

to Federal Rule of Civil Procedure 24(b). As grounds therefore, Cammy Depew states as follows:

1. Cammy Depews Motion to Intervene is timely because less than one year has passed

since the final order and judgment was filed in behalf of LNV Corporation against Catherine

Gebhardt in the amount of Three Hundred Eighty Nine Thousand Five Hundred Nine and

83/100 Dollars ($389,509.83).

2. Gebhardts Notice of Appeal has been entered and is pending, and Cammy Depews

intervention will not create any delay. Thus, intervention by Cammy Depew at this juncture

will not prejudice the existing parties.

3. Cammy Depew, as do other victims of Plaintiffs fraud and fraud upon the court, has a

substantial legal interest in the subject matter of the action because it involves claims of

violations of the Fifth and Fourteenth Amendment rights of due process under the Constitution

of the United States specific to deprivation of property; and claims of violations of Fourteenth

Amendment rights to equal protection of the law under the Constitution of the United States.

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4. Disposition of the action without the participation of Cammy Depew and the other

victims of same fraud, abuse of the courts and fraud upon the courts by LNV Corporation

(Plaintiff in this action) may impede general enforcement and regulatory interests in Federal

laws enacted to protect consumers. This case implicates stare decisis concerns that warrant the

intervention of other victims whose cases will be affected by the outcome of this case.

5. I, Cammy Depew am in litigation with LNV Corporation owned by D. Andrew Beal,

originating from a longstanding dispute over misappropriation of payments by MGC, false

default, fraudulent documents, and many other issues of material fact. LNV and their attorneys

also committed fraud upon the court in my case in the 23rd

Judicial District Court Parish of

Ascension State of Louisiana, Case No. 97357.

6. LNV filed for executory process in August 2010. The required evidence for use of

executory process in Louisiana was not provided with their petition however the courts have

relaxed the laws for so long that this has become common practice. I filed to postpone the

sheriff sale because I was in the process of a modification and had no idea there was a pending

sheriff sale until a couple days beforehand. A hearing was held on my petition to postpone on

July 9, 2012. It was denied due to procedural error. The judge did not say with prejudice,

however opposing counsel from Dean Morris Law firm, a LPS service provider, representing

LNV added with prejudice when he wrote the order for the judge.

In the absence of a direction that a dismissal is with prejudice, it is treated as a

dismissal without prejudice. State v. Faulkner, 30 Or App 1027, 568 P2d 714 (1977)

7. LNVs counsel filed the judgment on Friday August. 3, 2012 and certified that it was sent

to me via certified mail on Wednesday August 1, 2012. This judgment was signed by the judge

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on Monday August 6, 2012. This is in violation of La. District Court Rule 9.5 (b). As soon as

LNV violated La. District Court Rule 9.5 (b) they sold my house at sheriffs sale.

If presented later, the responsible attorney or the self-represented party shall circulate

the proposed judgment, order, or ruling to counsel for all parties and to self-represented

parties and allow at least five (5) working days for comment before presentation to the

court. When submitted, the proposed judgment, order, or ruling shall be accompanied

by a certificate stating: the date of mailing; the method of delivery of the document to

other counsel of record and to self-represented parties; whether any opposition was

received; and the nature of the opposition.

This action by opposing counsel was deliberate and calculated to deprive me of my due process

rights under constitutional law. This is a pattern for LNV Corporation and their attorneys across this

country. It is also a well known fact that individuals such Gebhardt are in continuous battle with

keeping adequate counsel on their behalf and the reasons can only be speculated at this point

however; it is a pattern in the majority of cases involving LNV.

8. At least 90% of Pro se litigants lose without ever having a hearing simply due to

procedure. The courts are supposed to help them with procedure but they dont. Refer to the

Louisiana pro se guidelines written in 2004 but NEVER implemented. Pro se litigants losing on

procedure alone when their cases have merit is a violation of due process and is

unconstitutional. Violation of due process is a state issue; a government issue, a federal issue, a

Constitutional issue and is a severe problem in this country.

9. Like in the Gebhardt case I was denied due process and equal protection of law under the

Constitution.

10. Cammy Depews interests and the interests of other victims of the crimes of LNV

Corporation and their attorneys as co-conspirators with Lorraine Brown who has already been

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criminally convicted, along with unknown co-conspirators, in favor of the United States for

these same crimes.

11. The interests of Cammy Depew and the other victims of the crimes of Brown, LNV

(Plaintiff in this case) and the other LPS service providers and their clients are not adequately

protected by the existing parties to the litigation. Because the interests of Cammy Depew and

the other victims represent a public interest on a national scale, the interests of the group do not

necessarily align with the interests represented by private plaintiffs.

12. Cammy Depew and the other victims satisfy the requirements for permissive intervention

because their claims against the Plaintiff, LNV, have questions of law and fact in common with

the claims and facts at issue in the main action, and the action involves the interpretation of

statutes that the Attorney General is entrusted by Congress to administer. See Fed. R. Civ. P.

24(b)(2).

RESPECTFULLY SUBMITTED on this _____ day of May, 2014

__________________________________________________________________

CAMMY DEPEW

42033 Janile Street

Gonzales, LA 70737

225-450-2348

23rd

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that the copy of the foregoing motion of the Defendant has

been forwarded by regular U.S. Mail upon the following:

Ronald G. Steen Jr. and

Kevin P. Hartley

STITES & HARBISON, PLLC

Sun Trust Plaza

401 Commerce Street

Suite 800

Nashville, Tennessee, 37219

Cathrine Gebhardt

3753 Thomas Cross Road

Sevierville, Tennessee, 37876

SUBMITTED on this _____ day of May, 2014

_________________________________________

CAMMY DEPEW

42033 Janile Street

Gonzales, LA 70737

225-450-2348

23rd