Foreclosure Defense FloridaGeneral Information

Request to Take Judicial Notice….The Lorriane Brown, DocxLLC/LPS Admission

The sad and terrifying reality is that courts all across this nation will continue to ignore the crimes committed by banks as they work on behalf of their masters to take property from Americans and throw them into the street.   For years, “our” government at all levels conspired with the criminal enterprises to re-define the crimes with terms like “surrogate signing“, but the guilty plea of the executive changes all of that.   The guilty plea makes the conspiracy clear.   And while one level of conspirators….the government enablers…is clear, the real question remains when the other level of conspirators….the bank clients…will be brought to any measure of justice…..
2. Under Fla. Stat. §90.206(5), the Court may take judicial notice of official actions
of the legislative, executive and judicial departments of the United States. Under Fla. Stat.
§90.202(6), the Court may take judicial notice of records of any court in this state or of any court
of record of the United States.
3. On November 20, 2012, Lorraine Brown, (” Brown”) a former executive of
Lender Processing Services, Inc. (LPS) and DocX LLC, a LPS company, pleaded guilty to
conspiracy to commit mail and wire fraud.
4. LPS and DocX LLC were involved in the preparation and recordation of
mortgage-related documents throughout the country since the 1990s.
5. SZYMONIAK moves this Court to take Judicial Notice of Brown’s information
and Plea Agreement because these documents confirm that DocX employees engaged in a
massive fraud in the preparation of hundreds of thousands of mortgage-related documents,
including Mortgage Assignments, and SZYMONIAK contends that the Mortgage Assignment
prepared and filed by DocX in her case, bearing the purported signature of Linda Green, was one
such fraudulent mortgage assignment.
6. By way of background, DocX was hired by residential mortgage servicers to
(among other things) assist in creating and executing mortgage-related documents filed with
recorders’ offices across the country.
7. Brown represented to DocX’s clients that DocX had robust quality control
procedures in place to ensure a thorough and proper signing, notarization, and recordation
8. Only specific personnel at DocX were authorized by clients to sign the
9. At the direction of Brown, employees of DocX, including those who were not
authorized to sign documents, began forging and falsifying signatures of the mortgage-related
documents that they had been hired to prepare and file with property recorders’ offices.
10. After these documents were falsely signed and falsely notarized, Brown
authorized DocX employees to file and record them with property records offices across the
11. Brown also hired temporary workers to sign as authorized signatures, and these
workers worked without the quality control represented by Brown to DocX’s clients.
12. Many of DoxX’s temporary employees signed thousands of mortgage
assignments each day, often signing the names of other persons on Mortgage Assignments that
would then be witnessed and notarized. These employees often signed as officers of banks and
mortgage companies. These employees signed without reading the documents or in any way
ascertaining the truth of the matters presented therein, including the grantor, grantee, and date of
the purported transfer.
13. Many of the documents, including mortgage assignments and lost note affidavits,
were later relied upon in court proceedings including foreclosure proceedings and federal
bankruptcy actions.
14. Brown admitted she understood that courts, property recorders, title insurers, and
homeowners relied upon the documents as genuine.
15. Brown implemented these signing practices at DocX to increase profits.
16. Between 2003 and 2009, DocX generated approximately $60 million in gross
17. Brown admitted that she and others took various steps to conceal their actions
from clients, law enforcement authorities, and others.
18. These steps to conceal included testing new employees to ensure they could
mimic [forge] signatures.
19. The documents attached hereto as Exhibits ” A” and ” B” may be accessed online
from PACER under United States of America v. Lorraine Brown, Criminal Docket # 3:12-cr-
20. Timely written notice of this request is hereby given by email service upon
Plaintiff’s counsel as required by Fla. Stat. §90.203.
WHEREFORE, pursuant to Fla. Stat. §90.202 and §90.203, Defendant LYNN
SZYMONIAK moves this Honorable Court to take judicial notice of the Information and Plea
Agreement of Lorraine Brown, United States of America v. Lorraine Brown, Case No. 3:12-cr-
198-J-25 MCR, (M.D. Fla.) without hearing, and for such other and further relief as this
Honorable Court deems just and proper under the circumstances.


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