Clark, et al v. Bank Of America, N.A., et al

Filing 71

MOTION for Leave to File Notice of Lawsuit by Ray M. Clark. (Attachments: # 1 Proposed Order, # 2 Proposed Waiver of Summons, # 3 Proposed Waiver of Summons). Motions referred to Judge Henry J. Bemporad. (rf)

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

RAY M. CLARK AND ZENAIDA CLARK,
PRO SE PLAINTIFFS,

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VS.

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SA-1 3-CA-28
FB (IIJB)

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BANK OF AMERICA, N.A., (BOA)
BANK OF AMERICA HOME LOANS,
COUNTRYWIDE HOME LOANS, AND
THEIR DESIGNATED EMPLOYEES
AND AGENTS IDENTIFIED AS:
1. EDWINA HITCHIN, ASSISTANT V. P.
BARRETT DAFFIN FRAPPIER TURNER and ENGEL LLP AS
DEBT COLLECTORS AND ATTORNEYS FOR BANK OF
AMERICA AND THEIR EMPLOYEES IDENTIFIED AS:
1. PAIGE BRYANT, EMPLOYEE ATTORNEY,
2. ELIZABETH MCDONALD, EMPLOYEE ATTORNEY
3. ASHLEY M. JUDD, EMPLOYEE ATTORNEY,
4. KIMBERLY BUTEAUD, EMPLOYEE ATTORNEY,
5. CLARK ROYLE, EMPLOYEE ATTORNEY,
6. TOM MISTELI, EMPLOYEE ATTORNEY,
7. RYAN BOURGEOIS, EMPLOYEE ATTORNEY,
8. ANTHONY VINCENT, EMPLOYEE ATTORNEY,
9. KIMBERLY HEMEN WAY, EMPLOYEE ATTORNEY
10. GREGORY SHANNON, EMPLOYEE ATTORNEY,
FIDELITY NATIONAL FINANCIAL, INC.
ALAMO TITLE COMPANY,
ALAMO TITLE INSURANCE COMPANY, AND
THEIR EMPLOYEES IDENTIFIED AS:
1. KATIE MCBREARTY, ESCROW ADMIN
2. EDDIE HALL, PRESIDENT
3. MICHAEL RICH, V.P. REGULATORY COUNSEL

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JOHN DOES AND JANE DOES DEFENDANTS, ET AL

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MOTION FOR LEAVE OF COURT TO FILE NOTICE OF LAWSUIT AND
REQUEST TO WAIVE SERVICE OF A SUMMONS UPON NAMED DEFENDANT
EDWINA HITCHIN, ASSISTANT VICE PRESIDENT, BANK OF AMERICA.

SUBJECT MATTER JURISDICTION:
Under 28 USC § 1331 - Removal of civil actions

TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, PRO SE PLAINTIFF, RAY M. CLARK (hereinafter known as

'CLARKS" and/or "PLAINTIFFS"), and hereby files this MOTION FOR LEAVE OF
COURT TO FILE NOTICE OF LAWSUIT AND REQUEST TO WAIVE SERVICE OF
A SUMMONS UPON NAMED DEFENDANT EDWINA HITCHIN, ASSISTANT

VICE PRESIDENT, FOR DEFENDANT BANK OF AMERICA, N. A. in response to a
recent correspondence with Defendant Bank of America, N. A.'s Lead Attorney of
Record, Britton L. Larison, McGlinchey Stafford, PLLC, that Edwina Hitchin, Assistant
Vice President, Bank of America, N. A. is not represented by his firm.

Respectfully submitted,

Clark, Pro Se Plaintiff
29461 No Le Hace Drive
Fair Oaks Ranch, TX 78015
rayclark gvtc . co
Ray

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Certification:
hereby certify under penalty of perjury that I sent by Certified Priority Mail,
Return Receipt Requested, a true and correct copy of this: MOTION FOR LEAVE OF
COURT TO FILE NOTICE OF LAWSUIT AND REQUEST TO WAIVE SERVICE OF
A SUMMONS UPON NAMED DEFENDANT EDWINA HITCHIN, ASSISTANT
VICE PRESIDENT, BANK OF AMERICA with a true and correct copy of Plaintiffs'
SEVENTH AMENDED PETITION to each of the below listed parties on this l4 day
of NOVEMBER, 2013.
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VIA:

CMRR# 701306000000143575332

To:

Edwina Hitchin
Assistant Vice President, Foreclosure Specialist
Bank of America, N. A. Mail Code PA-150-01-93
150 Allegheny Center Mall
Pittsburg, PA 152 12-5335

BY:

Ray M. Clark, Pro Se Plaintiff
29461 No Le Hace Drive
Fair Oaks Ranch, TX 78015
rayc1ar<c3)gvtc.com

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