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)

NOTICE OF LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS.

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

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

§
§
§

VS.

§
§
§

BANK OF AMERICA, N.A., (BOA)
BANK OF AMERICA HOME LOANS,
COUNTRYWIDE HOME LOANS, AND
THEIR DESIGNATED EMPLOYEES
AND AGENTS IDENTIFIED AS:
3. 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:
21. PAIGE BRYANT, EMPLOYEE ATTORNEY,
22. ELIZABETH MCDONALD, EMPLOYEE ATTORNEY
23. ASHLEY M. JUDD, EMPLOYEE ATTORNEY,
24. KIMBERLY BUTEAUD, EMPLOYEE ATTORNEY,
25. CLARK ROYLE, EMPLOYEE ATTORNEY,
26. TOM MISTELI, EMPLOYEE ATTORNEY,
27. RYAN BOURGEOIS, EMPLOYEE ATTORNEY,
28. ANTHONY VINCENT, EMPLOYEE ATTORNEY,
29. KIMBERLY HEMEN WAY, EMPLOYEE ATTORNEY
30. GREGORY SHANNON, EMPLOYEE ATTORNEY,
FIDELITY NATIONAL FINANCIAL, INC.
ALAMO TITLE COMPANY,
ALAMO TITLE INSURANCE COMPANY, AND
THEIR EMPLOYEES IDENTIFIED AS:
7. KATIE MCBREARTY, ESCROW ADMIN
8. EDDIE HALL, PRESIDENT
9. MICHAEL RICH, V.P. REGULATORY COUNSEL

§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§

JOHN DOES AND JANE DOES DEFENDANTS, ET AL

§

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

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 15212-5335

We hereby submit this Request to Waive Service of Summons upon you.

This is not a summons, or an official notice from the court. It is a request
that, to avoid expenses, you waive formal service of summons by signing and
returning the enclosed waiver. To avoid these expenses, you must return the signed
waiver within 30 days from the date shown below, which is the date this notice was
sent. Two copies of the waiver forms are enclosed, along with a stamped, selfaddressed envelope or other means for returning one copy. You may keep the other
copy.
If you return the signed waiver, I will file it with the court. The action will
then proceed as if you had been served on the date the waiver is filed, but no
summons will be served on you and you will have 60 days from the date of this
notice is sent to answer the complaint.
If you do not return the signed waiver within the time indicated, I will

arrange to have the summons and complaint served on you. And I will ask the court
to require you, or the entity you represent, to pay the expense of making service.
Please read the enclosed statement about the duty to avoid unnecessary
expenses.
I

certify that this request is being sent to you on the date below.

Novemberl4,2013.

'-7

/(4-7 /I
Ray M. clark, Pro Se Plaintiff
29461 No Le Hace Drive
Fair Oaks Ranch, TX 78015
1'ayc1drk(()g\/t.cconi

[phone]

Attachment 1.
Attachment 2.
Attachment 3.

Duty to avoid Unnecessary Expenses of Serving a Summons,
Plaintiffs Seventh Amended Petition.
Exhibits filed in this Court by Defendant Bank of America.