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Cause No. 141-256938-11
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In the Interest of: Rodney L Wagner and all assets thereof. :X:
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In reference of the replevin done in a hardship due to unlawful set up. ~:r. g ?:J
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Rodney L Wagner § ,..,r-4 ,....
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2643 Coastline Drive, it'\::.: ~
Grand Prairie, Texas 75054 § "'r
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Affiant/Petitioner § IN THE DISTRICT COURT
§
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§ i l l _ JUDICIAL DISTRICT
-vs- §
BANK OF AMERICANA and all successors, et al §
CORPORATION, §
BANK OF AMERICA HOME LOANS SERVICING LP §
BAC HOME LOAN SERVICING, §
COUNTRYWIDE BANK FSB, §
MORTGAGE ELECTRONIC REGISTRATION §
SYSTEMS INC., §
BARRETI DAFFIN FRAPPIER TURNER & ENGEL §
LLP & TOMMY BASTIAN, §
FEDERAL NATIONAL MORTGAGE ASSOCIATION §
AKA/FANNIE MAE §
Respondents § TARRANT COUNTY, TEXAS
All interested parties
NOTICE OF REPLEVIN, DUE TO ALL ATTACHED EXHIBIT)
NOTICE TO CEASE AND DESIST ANY ALL FURTHER CORPORATE ACTIONS
NOTICE OF COMLAINT DUE TO UNLAWFUL SIGNED. NON-SEALED SIGNED
CITATIONS FROM THE OFFICE OF THE TARRANT COUNTY CLERK OFFICE AND
OFFICE OF THE CONSTABLES OF TARRANT COUNTY. TEXAS, CAUSING A
UNLA WFULL SET OUT.
Page 1 of 3
VERIFIED NOTICE TO CEASE AND DESIST ANY All FUTHER CORPORATE ACTIONS;
To: said independent Court, and all judicial offices, officers, associations, , Clerk and
private corporation operating out the District of Columbia through and by
Secretary of the State.
PLEAES TAKE NOTICE: That Rodney L Wagner /affiant has reserved all rights relating to the above
reference matters for all reasons stated and incorporated in the above reference notice.
PLEAES TAKE NOTICE: Respondent exercised an unlawful forcible entry and detainer of the owner
while a Temporary Restraining Order was active.
Sincerely,
--~ ~~- u~
Rod'lleit. Wagner
CERTIFICATE OF SERVICE
Applicant request that the clerk immediately preparer citations up on the filing of this
notice of Replevin etc., to all Respondents. With all due respect I certifY that a true and
correct copy has been sent in good faith to the responsible person/Affiant by the claimant.
BANK OF AMERICANA Counselors at law: c/o Blank Rome LLP. 1 Logan Square, 130 North
1
18 h Street, Philadelphia, PA 19103-6998.
FEDERAL NATIONAL MORTGAGE ASSOCIATION A/KIA FANNIE MAE, 13150 World
Gate, Drive, Herndon VA, 20170
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. et al CORPORATION
P.O.BOX 2026, FLINT, MI 48501-2026.
BARRETT DAFFIN FRAPPIER TURNER & ENGLE, LLP TOMMY BASTIAN, J. CLARK,
R. FRANK, T ROSS AND HOLLAND'S C/0 MARIS AND LANIER 3710 RAWLINS
STREET, SUITE 1550, DALLAS TEAXS, 75219.
State of Texas
County of Tarrant
Page 2 of3
VERIFIED NOTICE TO CEASE AND DESIST ANY ALL FUTHER CORPORATE ACTIONS;
ubscribed and sworn to
1
before me on this ;I-/ day of ~ , 2012, by
..L-J..l...Ll.l:...-'.A,--J==-""d...~'~".J.I(i.,J4lf-ll.4--J
proved to me on the basis ~f satisfacto evidence to be the
me, with above notice relating to the reference matter.
"!:ANesHA V. HARRISON
COMMiSSION EXPIRES
. ~18,2014
Page 3 of3
VERIFIED NOTICE TO CEASE AND DESIST ANY All FUTHER CORPORATE ACTIONS;
--
No.141 !57541 12
Rodney L Wagner §
§
Applicant §
§
§ IN THE DISTRICT COURT
§
•VS• §
FEDERAL NATIONAL MORTGAGE §
ASSOCIATION, NKIA FANNU:l MAE, §
OFFICERS, AGENTS, ASSIGNEES, §
ASSOCIATES, ETC., §
141 DISTRICT COURT CAUSE NO 256938-1 §
OFFICERS, AGENTS, ASSIGNEES, §
ASSOCIATES, ASSOCIATES, ETC., !i
JUSTICE ()F THE PEASE COURT §
PRECINCT 7 CAUSE NO JP07-11-l::00063773 §
OFFICERS, AGENTS, ASSIGNEES, §
ASSOCIATES, eTC., §
OFFICE OF THE CONSTABLE TARRANT §
COUN1Y PRECINCT 7, ITS, OFFICERS §
AGENTS, ASSIGNEES, ASSOCIATES, ETC.,§
§
Respondents § TARRANTCOUN1Y, TEXAS
APPLICATION ANO AFFIDAVIT FOR TEMPORARY RESTRAINING
ORDER AND PERMANENT INJUNCTION and Application Rescission of the. Forcible
entry and Detainer. by Bill of Review under Bill, etc.,
Notice: Application to vacate the order for the lorcible entry detainer and the
order denying the injWlction due to Applicants reservation of rights and Bill of Rights 1 .g and
Writ ol' Rights and for all other reasons stated and incorporated by thi~ Temporary Restraining
Order and Permanent Injw1ction.
1. Parties.,
a. Applkanl, Rodney L Wagner, an Individual whose address is, 2643
Coastline Drive, Grand Prairie, TX 75054, makes this Application for Temporary Restraining
Order and Tempcnuy Injunction.
b. The last three numbers of Rodney L Wagner, social security number are
199.
c. Respondents, through and by Its, OHicers, Agents, Assignees, Associates.
etc., may be served at the locations listed below:
Federal National Mortgage Association, Its, Agents, Officers Assignees, Associates. etc., is a
business who is operating in Texas, who may be served with process at: 3900 Wisconsin Ave,
North West Washingtrccinct 7 cause no JP07-Il-E00063773 and orders may be
served at 1100 East Broad Street, Suite 202, Mansfield Texas 76063.
Office of the Constable Tarrant County Precinct 7 may be served at 1100 East Broad Street,
Suit~ 20 I, Mansfield Texas 76063.
Service of said Respondent as described above can be affected by certified rentrn receipt mail tor
delivery.
2. This court has jurisdiction over the parties hecausc Respondents are op~rating in
Texas.
3. Applicant has not been able to contact CoUlltrywide Bank FSB/ Bank of America
NA the original Lender relating to the wet signature to the Original Note and Applicant home has
been wrongfully foreclosed on and has entered in a ulllawful agreement under duress under
Jinancial hardship.
In this suit, now pending in this Court, Applicant is seeking damages from Respondent.
4. Fraud and Misrepresentation.
Applicant will suft\:r immediate and irreparable injury, loss, or damage if Applicant
conduct described above is not enjoined for these reasons: Applicant is about to be unlawfully
evicted from Applicants home.
Applicant docs not have an adequate remedy at law because of the time. Applicant has
exercised it rights hy tiling for TRO, etc. The injury to Applicant if Respondent continues the
conduct described above would outweigh any injury the restraining order and injunction might
cause Respondent, and issuance of the reslr<~ining order and injunction would not disserve the
public interest.
5. Conditions Prcco:dcnt. All conditions precedent has been performed or has
occurred.
6. This attempt is made in order to stop an unlawful debt by the Respondent. Any
information obtained will bt: used for that purpose.
Application Rescission of the. Forcible entry and Detainer, hy Bill of Review under Bill of
Right amendments 1-11, and due to fraud (intentional Deception)
7. Prayer.
Applicant prays that actions be restrain immediately upon this filing:
a. Without notice to Respondents, the Court issue a tempurary restraining
order restraining Respondt:nt and his officers, agents, servants, and employees from directly (>r
indirectly from evicting Applicant .
Affidllvit
BEFORE ME, the undersigned !IUthority, on this day personally appeared Rodney L
Wagner who swore on oath that the following facts are true:
"I am Applicant in this cause. I have personal knowledge of the facts stattld above, and
they are true and correct." I request that the clerk immediately set hearing and issue Notice and
citations upon the filing of Applicant Application.
Rodney L. W11gner
Affillllt
SlONE[) tmder oath before me on\~ JJ 11 Wkll1 fJ) Z-
l-~ .I /A J< ~a\( ~~11 AA1 ~J:r..
otary Public, Sb{te of Texas
b. the Court set a date and time for a hearing on this application for a
pennanent i~i unction;
c. Respondent is cited to appear and an~wer;
d. Al'ler hearing, the Court issues a permanent injunction cJ~oin.ing
Respondent and his officers, agents, servants, and employees lh1m directly or indirectly relating
to the eviction during the pendency of this action;
Applicant be granted reasonable expenses incurred in obtaining the restraining order and
injunction; and
Applicant be granted all further relief to which Applicant may be entitled.
Respe~-tfully submitted,
By~~ d4·,LJ '):
Rodney L~agner
2643 Coastline Drive
Grand Prairie TX 75054
214-803-4513
NOTICE OF HRARTNG
The above and foregoing Applicant Temporary Injunction is set for hearing on _ _ _
_ at _ _, in the __ Judicial District Court of Tarrant County, Texas.
Clerk
Preview
i l~ Cause No. 141-256938-11 -1 :;; In the Interest of: Rodney L Wagner and all assets thereof. :X: 0 ''"t'\ """ ?:J In reference of the replevin done in a hardship due to unlawful set up. ~:r. g ?:J :P..,-, ~Y' ~U'' -:-1 ..,_'""' -.1 __,,rr, :t:- ...-.1,.•...-' Rodney L Wagner § ,..,r-4 ,.... -o :X "o 0 § c: 2643 Coastline Drive, it'\::.: ~ Grand Prairie, Texas 75054 § "'r ,o N § $" r'l § :::0 § Affiant/Petitioner § IN THE DISTRICT COURT § § § i l l _ JUDICIAL DISTRICT -vs- § BANK OF AMERICANA and all successors, et al § CORPORATION, § BANK OF AMERICA HOME LOANS SERVICING LP § BAC HOME LOAN SERVICING, § COUNTRYWIDE BANK FSB, § MORTGAGE ELECTRONIC REGISTRATION § SYSTEMS INC., § BARRETI DAFFIN FRAPPIER TURNER & ENGEL § LLP & TOMMY BASTIAN, § FEDERAL NATIONAL MORTGAGE ASSOCIATION § AKA/FANNIE MAE § Respondents § TARRANT COUNTY, TEXAS All interested parties NOTICE OF REPLEVIN, DUE TO ALL ATTACHED EXHIBIT) NOTICE TO CEASE AND DESIST ANY ALL FURTHER CORPORATE ACTIONS NOTICE OF COMLAINT DUE TO UNLAWFUL SIGNED. NON-SEALED SIGNED CITATIONS FROM THE OFFICE OF THE TARRANT COUNTY CLERK OFFICE AND OFFICE OF THE CONSTABLES OF TARRANT COUNTY. TEXAS, CAUSING A UNLA WFULL SET OUT. Page 1 of 3 VERIFIED NOTICE TO CEASE AND DESIST ANY All FUTHER CORPORATE ACTIONS; To: said independent Court, and all judicial offices, officers, associations, , Clerk and private corporation operating out the District of Columbia through and by Secretary of the State. PLEAES TAKE NOTICE: That Rodney L Wagner /affiant has reserved all rights relating to the above reference matters for all reasons stated and incorporated in the above reference notice. PLEAES TAKE NOTICE: Respondent exercised an unlawful forcible entry and detainer of the owner while a Temporary Restraining Order was active. Sincerely, --~ ~~- u~ Rod'lleit. Wagner CERTIFICATE OF SERVICE Applicant request that the clerk immediately preparer citations up on the filing of this notice of Replevin etc., to all Respondents. With all due respect I certifY that a true and correct copy has been sent in good faith to the responsible person/Affiant by the claimant. BANK OF AMERICANA Counselors at law: c/o Blank Rome LLP. 1 Logan Square, 130 North 1 18 h Street, Philadelphia, PA 19103-6998. FEDERAL NATIONAL MORTGAGE ASSOCIATION A/KIA FANNIE MAE, 13150 World Gate, Drive, Herndon VA, 20170 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. et al CORPORATION P.O.BOX 2026, FLINT, MI 48501-2026. BARRETT DAFFIN FRAPPIER TURNER & ENGLE, LLP TOMMY BASTIAN, J. CLARK, R. FRANK, T ROSS AND HOLLAND'S C/0 MARIS AND LANIER 3710 RAWLINS STREET, SUITE 1550, DALLAS TEAXS, 75219. State of Texas County of Tarrant Page 2 of3 VERIFIED NOTICE TO CEASE AND DESIST ANY ALL FUTHER CORPORATE ACTIONS; ubscribed and sworn to 1 before me on this ;I-/ day of ~ , 2012, by ..L-J..l...Ll.l:...-'.A,--J==-""d...~'~".J.I(i.,J4lf-ll.4--J proved to me on the basis ~f satisfacto evidence to be the me, with above notice relating to the reference matter. "!:ANesHA V. HARRISON COMMiSSION EXPIRES . ~18,2014 Page 3 of3 VERIFIED NOTICE TO CEASE AND DESIST ANY All FUTHER CORPORATE ACTIONS; -- No.141 !57541 12 Rodney L Wagner § § Applicant § § § IN THE DISTRICT COURT § •VS• § FEDERAL NATIONAL MORTGAGE § ASSOCIATION, NKIA FANNU:l MAE, § OFFICERS, AGENTS, ASSIGNEES, § ASSOCIATES, ETC., § 141 DISTRICT COURT CAUSE NO 256938-1 § OFFICERS, AGENTS, ASSIGNEES, § ASSOCIATES, ASSOCIATES, ETC., !i JUSTICE ()F THE PEASE COURT § PRECINCT 7 CAUSE NO JP07-11-l::00063773 § OFFICERS, AGENTS, ASSIGNEES, § ASSOCIATES, eTC., § OFFICE OF THE CONSTABLE TARRANT § COUN1Y PRECINCT 7, ITS, OFFICERS § AGENTS, ASSIGNEES, ASSOCIATES, ETC.,§ § Respondents § TARRANTCOUN1Y, TEXAS APPLICATION ANO AFFIDAVIT FOR TEMPORARY RESTRAINING ORDER AND PERMANENT INJUNCTION and Application Rescission of the. Forcible entry and Detainer. by Bill of Review under Bill, etc., Notice: Application to vacate the order for the lorcible entry detainer and the order denying the injWlction due to Applicants reservation of rights and Bill of Rights 1 .g and Writ ol' Rights and for all other reasons stated and incorporated by thi~ Temporary Restraining Order and Permanent Injw1ction. 1. Parties., a. Applkanl, Rodney L Wagner, an Individual whose address is, 2643 Coastline Drive, Grand Prairie, TX 75054, makes this Application for Temporary Restraining Order and Tempcnuy Injunction. b. The last three numbers of Rodney L Wagner, social security number are 199. c. Respondents, through and by Its, OHicers, Agents, Assignees, Associates. etc., may be served at the locations listed below: Federal National Mortgage Association, Its, Agents, Officers Assignees, Associates. etc., is a business who is operating in Texas, who may be served with process at: 3900 Wisconsin Ave, North West Washingtrccinct 7 cause no JP07-Il-E00063773 and orders may be served at 1100 East Broad Street, Suite 202, Mansfield Texas 76063. Office of the Constable Tarrant County Precinct 7 may be served at 1100 East Broad Street, Suit~ 20 I, Mansfield Texas 76063. Service of said Respondent as described above can be affected by certified rentrn receipt mail tor delivery. 2. This court has jurisdiction over the parties hecausc Respondents are op~rating in Texas. 3. Applicant has not been able to contact CoUlltrywide Bank FSB/ Bank of America NA the original Lender relating to the wet signature to the Original Note and Applicant home has been wrongfully foreclosed on and has entered in a ulllawful agreement under duress under Jinancial hardship. In this suit, now pending in this Court, Applicant is seeking damages from Respondent. 4. Fraud and Misrepresentation. Applicant will suft\:r immediate and irreparable injury, loss, or damage if Applicant conduct described above is not enjoined for these reasons: Applicant is about to be unlawfully evicted from Applicants home. Applicant docs not have an adequate remedy at law because of the time. Applicant has exercised it rights hy tiling for TRO, etc. The injury to Applicant if Respondent continues the conduct described above would outweigh any injury the restraining order and injunction might cause Respondent, and issuance of the reslr<~ining order and injunction would not disserve the public interest. 5. Conditions Prcco:dcnt. All conditions precedent has been performed or has occurred. 6. This attempt is made in order to stop an unlawful debt by the Respondent. Any information obtained will bt: used for that purpose. Application Rescission of the. Forcible entry and Detainer, hy Bill of Review under Bill of Right amendments 1-11, and due to fraud (intentional Deception) 7. Prayer. Applicant prays that actions be restrain immediately upon this filing: a. Without notice to Respondents, the Court issue a tempurary restraining order restraining Respondt:nt and his officers, agents, servants, and employees from directly (>r indirectly from evicting Applicant . Affidllvit BEFORE ME, the undersigned !IUthority, on this day personally appeared Rodney L Wagner who swore on oath that the following facts are true: "I am Applicant in this cause. I have personal knowledge of the facts stattld above, and they are true and correct." I request that the clerk immediately set hearing and issue Notice and citations upon the filing of Applicant Application. Rodney L. W11gner Affillllt SlONE[) tmder oath before me on\~ JJ 11 Wkll1 fJ) Z- l-~ .I /A J< ~a\( ~~11 AA1 ~J:r.. otary Public, Sb{te of Texas b. the Court set a date and time for a hearing on this application for a pennanent i~i unction; c. Respondent is cited to appear and an~wer; d. Al'ler hearing, the Court issues a permanent injunction cJ~oin.ing Respondent and his officers, agents, servants, and employees lh1m directly or indirectly relating to the eviction during the pendency of this action; Applicant be granted reasonable expenses incurred in obtaining the restraining order and injunction; and Applicant be granted all further relief to which Applicant may be entitled. Respe~-tfully submitted, By~~ d4·,LJ '): Rodney L~agner 2643 Coastline Drive Grand Prairie TX 75054 214-803-4513 NOTICE OF HRARTNG The above and foregoing Applicant Temporary Injunction is set for hearing on _ _ _ _ at _ _, in the __ Judicial District Court of Tarrant County, Texas. Clerk