[ATTACHED] EXHIBITS September 24, 2020

On August 14, 2020 a Exhibit,Appendix was filed involving a dispute between and for CONTRACT, OTHER CONTRACT in the District Court of Tarrant County.

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348-318654-20

Exhibit 1
Case 4:20-cv-01057-P Document 1 Filed 09/24/20 Page 1 of 8 PageID 1

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

TONY HOA LAM §
§
Plaintiff, §
§
v. §
CIVIL ACTION NO. ___________
§
WELLS FARGO BANK, N.A. §
§
Defendant. §

NOTICE OF REMOVAL

Pursuant to 28 U.S.C. §§ 1332(a), 1441, and 1446, Defendant Wells Fargo Bank, N.A.

(“Defendant”) removes this action from the 348th Judicial District Court, Tarrant County, Texas

to the United States District Court for the Northern District of Texas, Fort Worth Division, as

follows:

I. STATE COURT ACTION

1. On August 14, 2020, Plaintiff Tony Hoa Lam ("Plaintiff") filed his Original

Petition for Declaratory Judgment (the "Petition") in the 348th Judicial District Court, Tarrant

County, Texas, styled: Tony Hoa Lam v. Wells Fargo Bank, N.A., Cause No. 348-318654-20 (the

"State Court Action").

2. In the State Court Action, Plaintiff seeks to quiet title to the property located at

5225 N. Hampshire Blvd., Fort Worth, Texas (the "Property"). Plaintiff seeks declarations from

the Court that the underlying promissory note has matured and that because more than four (4)

years has elapsed since the note allegedly matured, Wells Fargo cannot enforce the Note and Deed

of Trust. He seeks cancellation of the debt, a release of lien, and attorneys’ fees.

NOTICE OF REMOVAL PAGE 1
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3. Defendant was served on August 21, 2020. See Docket Sheet (Ex. C). Defendant

filed its Original Answer on September 11, 2020. Answer (Ex. C-3). Therefore, this Notice of

Removal is timely under 28 U.S.C. §§ 1446(b)(1), 1446(b)(2)(B).

4. Defendant removes the State Court Action to this Court on the basis of diversity

jurisdiction.

II. PROCEDURAL REQUIREMENTS

5. This action is properly removed to this Court, as the lawsuit is pending within the

district and division. See 28 U.S.C. § 1441; 28 U.S.C. § 124(a)(2).

6. The United States District Court for the Northern District of Texas, Fort Worth

Division, has original jurisdiction over this action based on diversity jurisdiction because

Defendant is now, and was at the time this action commenced, diverse in citizenship from Plaintiff,

and the amount in controversy exceeds the minimum jurisdictional amount. See 28 U.S.C. §

1332(a).

7. Pursuant to 28 U.S.C. § 1446(a) and Northern District of Texas Local Rule CV-

81.1, this Notice of Removal is accompanied by copies of the following materials:

Exhibit A Index of Matters Being Filed

Exhibit B Civil Cover Sheet

Exhibit B-1 Supplemental Civil Cover Sheet

Exhibit C State Court docket sheet

Exhibit C-1 Plaintiff’s Original Petition

Exhibit C-2 Defendant’s Original Answer

Exhibit D Tarrant County Appraisal District property information

NOTICE OF REMOVAL PAGE 2
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8. Defendant is filing a copy of the Notice of Removal in the 348th Judicial District

Court, Tarant County, Texas pursuant to 28 U.S.C. § 1446(d).

III. DIVERSITY JURISDICTION

9. Where there is complete diversity among the parties and the amount in controversy

exceeds $75,000, exclusive of interest and costs, an action may be removed to federal court. See

28 U.S.C. §§ 1332(a), 1441(a). Complete diversity exists in this case because Plaintiff is not a

citizen of the same state as Defendant. Additionally, this action involves an amount in controversy

that exceeds $75,000, exclusive of interest and costs.

A. THE PARTIES ARE COMPLETELY DIVERSE

10. Plaintiff is a natural person, so his citizenship for diversity purposes is determined

by "where [he is] domiciled, that is,where [he has] a fixed residence with the intent to remain

there indefinitely." Margetis v. Ray, No. 3:08-CV-958-L, 2009 WL 464962, at *3 (N.D. Tex. Feb.

25, 2009) (citing Freeman v. Northwest Acceptance Corp., 754 F.2d 553, 555-56 (5th Cir. 1985)).

Plaintiff is domiciled in Denton County, Texas. See Petition, ¶ 2.01 (Ex. C-1). Therefore, Plaintiff

is a citizen of Texas for diversity purposes.

11. Wells Fargo is a national banking association organized under federal law. A

national bank, for diversity purposes, "is a citizen of the State in which its main office, as set forth

in its articles of association, is located." Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303, 307

(2006). Under its articles of association, Wells Fargo's main office is located in South Dakota.

Therefore, Wells Fargo is a citizen of South Dakota for diversity purposes. 28 U.S.C. § 1348;

Wachovia Bank, 546 U.S. at 307.

NOTICE OF REMOVAL PAGE 3
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B. AMOUNT IN CONTROVERSY IS SATISFIED

12. Where a defendant can show, by a preponderance of the evidence, that the amount

in controversy more likely than not exceeds the jurisdictional minimum, removal is proper. See

White v. FCI U.S.A., Inc., 319 F.3d 672, 675–76 (5th Cir. 2003); see also St. Paul Reins. Co. v.

Greenberg, 134 F.3d 1250, 1253 n.13 (5th Cir. 1998) (“The test is whether it is more likely than

not that the amount of the claim will exceed [the jurisdictional minimum].”). A defendant can meet

this burden if it is apparent from the face of the petition that the claims are likely to exceed $75,000,

or, alternatively, if the defendant introduces other evidence to show that the amount in controversy

more likely than not exceeds $75,000, exclusive of interest and costs. See Greenberg, 134 F.3d at

1253; Berry v. Chase Home Fin., LLC, No. C-09-116, 2009 WL 2868224, at *2 (S.D. Tex. Aug.

27, 2009).

13. “In actions seeking declaratory or injunctive relief, itis well established that the

amount in controversy is measured by the value of the object of the litigation.” Farkas v. GMAC

Mortgage, LLC, 737 F.3d 338, 341(5th Cir. 2013) (quoting Hunt v. Wash. State Apple Adver.

Comm'n, 432 U.S. 333, 347 (1977)); Martinez v. BAC Home Loans Servicing, 777 F. Supp. 2d.

1039, 1044 (W.D. Tex. 2010). Specifically, the Farkas Court held that: “[i]n actions enjoining a

lender from transferring property and preserving an individual's ownership interest, it is the

property itself that is the object of the litigation; the value of that property represents the amount

in controversy.” Id. (citing Garfinkle v. Wells Fargo Bank, 483 F.2d 1074, 1076 (9th Cir. 1973)).

Thus, “‘[w]hen . . . a right to property is called into question in its entirety, the value of the property

controls the amount in controversy.’” Nationstar Mortgage LLC v. Knox, No. 08-60887, 351 F.

App'x 844, 848 (5th Cir. 2009) (quoting Waller v. Prof’l Ins. Corp., 296 F.2d 545, 547-48 (5th

Cir. 1961)); see also Alsobrook v. GMAC Mortg., L.L.C., 541 F. App’x. 340, 342 n.2, (5th Cir.

NOTICE OF REMOVAL PAGE 4
83628452V.1
Case 4:20-cv-01057-P Document 1 Filed 09/24/20 Page 5 of 8 PageID 5

2013); Copeland v. U.S. Bank Nat’l Ass’n, No. 11-51206, 485 F. App’x 8, 9 (5th Cir. 2012) (relying

on the value of the property to satisfy the amount in controversy in exercising diversity jurisdiction

over appeal of foreclosure-related claims).

14. Plaintiff also seeks to recover attorney’s fees. See Petition, ¶ 5.09 (Ex. C-1). The

attorneys’ fees must also be included in the amount in controversy. White, 319 F.3d at 675-77

(affirming a district court’s finding that attorney fees are part of the amount in controversy

(quotation omitted); Grant, 309 F.3d 864, 874 (“[W]e hold that when there is state statutory

authority for the court to award attorney’s fees . . . ‘such fees may be included in the amount in

controversy.’”) (quotation omitted); Ray Mart, Inc. v. Stock Bldg. Supply of Texas, L.P., 435 F.

Supp. 2d 578, 588 (E.D. Tex. 2006) (including potential award of attorney fees in calculating the

amount in controversy).

15. Based on a review of the Petition and the evidence presented, the amount in

controversy more likely than not exceeds $75,000, exclusive of interest and costs. Plaintiff seeks

declarations from the Court that the underlying promissory note has matured and that because

more than four (4) years has elapsed since the note allegedly matured, Wells Fargo cannot enforce

its rights under the Note and Deed of Trust. Plaintiff alleges that the value of the debt that he

should not be required to pay is no less than $62,582.56. See Petition, ¶ 5.06 (Ex. C-1). Moreover,

because Plaintiff seeks to halt Wells Fargo from enforcing its rights in the Note and Deed of Trust,

the value of the Property is an appropriate measure of the amount in controversy. See Bardwell v.

BAC Home Loans Servicing, LP, No. 3:11-CV-1002-B, 2011 WL 4346328, at *2 (N.D. Tex. Sept.

16, 2011) (finding value of the property at issue was an appropriate measure of the amount in

controversy where the plaintiff sought to preclude the defendants from exercising their rights in

the property); Nationstar Mortgage LLC, 351 Fed. App’x at 848; Martinez, 777 F. Supp. 2d at

NOTICE OF REMOVAL PAGE 5
83628452V.1
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1047; Waller, 296 F.2d at 547-48. According to the Tarrant County Appraisal District, the current

tax assessed value of the Property is $58,000.00.1 See Ex. D. Further, in addition to seeking

cancellation of the debt and a release of lien, Plaintiff seeks attorneys’ fees. See Petition, ¶ 5.09

(Ex. C-1). Based on Plaintiff’s request for cancellation of the debt and attorneys’ fees, the amount

in controversy more likely than not exceeds $75,000, exclusive of interest and costs.

16. Because there is complete diversity among the parties and because the amount in

controversy requirement is satisfied, this Court has jurisdiction pursuant to 28 U.S.C. §§ 1332,

1441, and 1446. Therefore, removal is proper.

IV. CONCLUSION

WHEREFORE, Defendant Wells Fargo Bank, N.A. removes this action from the 348th

Judicial District, Tarrant County, Texas to the United States District Court for the Northern District

of Texas, Fort Worth Division so that this Court may assume jurisdiction over the cause as

provided by law.

1
Pursuant to Rule 201 of the Federal Rules of Evidence, Defendant respectfully requests that the Court take judicial
notice of the Tarrant County Appraisal District valuation for the Property.

NOTICE OF REMOVAL PAGE 6
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Respectfully submitted,

LOCKE LORD LLP

/s/ Jennifer McCammon
Robert T. Mowrey (Attorney-in-Charge)
State Bar No. 14607500
rmowrey@lockelord.com
Matthew H. Davis
State Bar No. 24069580
mdavis@lockelord.com
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201-6776
(214) 740-8000
(214) 740-8800 (facsimile)

Jennifer McCammon
State Bar No. 24101983
Jennifer.mccammon@lockelord.com
JPMorgan Chase Tower
600 Travis Street, Suite 2800
Houston, Texas 77002
Telephone: (713) 226-1511
Facsimile: (713) 229-2578

COUNSEL FOR DEFENDANT

NOTICE OF REMOVAL PAGE 7
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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was served upon
the following counsel via ECF pursuant to the Federal Rules of Civil Procedure on September 24,
2020.

Kent Canada
Law Office of Christopher J. Sullivan, PLLC
2011 Lakeside Parkway
Flower Mound, Texas 75028
Counsel for Plaintiff

/s/ Jennifer McCammon
Jennifer McCammon

NOTICE OF REMOVAL PAGE 8
83628452V.1
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Exhibit A

83628790v.1
Case 4:20-cv-01057-P Document 1-1 Filed 09/24/20 Page 2 of 2 PageID 10

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

TONY HOA LAM §
§
Plaintiff, §
§
v. §
CIVIL ACTION NO. ___________
§
WELLS FARGO BANK, N.A. §
§
Defendant. §

INDEX OF MATTERS BEING FILED

Pursuant to Northern District of Texas Local Rules 81.1, Defendant Wells Fargo Bank,

N.A. files the following exhibits in support of its Notice of Removal:

Exhibit A Index of Matters Being Filed

Exhibit B Civil Cover Sheet

Exhibit B-1 Supplemental Civil Cover Sheet

Exhibit C State Court docket sheet

Exhibit C-1 Plaintiff’s Original Petition

Exhibit C-2 Defendant’s Original Answer

Exhibit D Tarrant County Appraisal District property
information

______________________________________________________________________________
INDEX OF MATTERS BEING FILED Page 1
83628790v.1
Case 4:20-cv-01057-P Document 1-2 Filed 09/24/20 Page 1 of 3 PageID 11

Exhibit B
JS 44(Rev. 06/17) - TXND (Rev. 06/17) CIVIL COVER SHEET
Case 4:20-cv-01057-P Document 1-2 Filed 09/24/20 Page 2 of 3 PageID 12
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet.
(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS
Tony Hoa Lam Wells Fargo Bank, N.A.

(b) Denton County, Texas
County of Residence of First Listed Plaintiff Minnehaha County, SD
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Law Office of Christopher J. Sullivan, PLLC, 2011 Lakeside Parkway, Flower Locke Lord LLP, 2200 Ross Avenue, Suite 2800, Dallas, Texas 75201,
Mound, Texas 75028, (214) 784-9900 (214) -740-8000

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 ’
Incorporated or Principal Place
4 ’ 4
of Business In This State

’ 2 U.S. Government ’ 4 Diversity ’
Citizen of Another State 2 ’ 2 ’
Incorporated and Principal Place
5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

’
Citizen or Subject of a 3 ’ 3 Foreign Nation ’ 6 ’ 6
Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure
’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - ’ 423 Withdrawal
of Property 21 USC 881 ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product ’ 690 Other
Product Liability 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ ’
150 Recovery of Overpayment
320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated
’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards
’ 861 HIA (1395ff) ’ 490 Cable/Sat TV
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) ’ 850 Securities/Commodities/
’ 190 Other Contract Product Liability’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) Exchange
’ ’
195 Contract Product Liability
360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 890 Other Statutory Actions
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 891 Agricultural Acts
’ 362 Personal Injury - Product Liability’ 751 Family and Medical ’ 893 Environmental Matters
Medical Malpractice Leave Act ’ 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation
FEDERAL TAX SUITS Act
’ 210 Land Condemnation ’ 440 Other Civil RightsHabeas Corpus: ’ 791 Employee Retirement
’ 870 Taxes (U.S. Plaintiff
’ 896 Arbitration
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) ’ 899 Administrative Procedure
’ ’
230 Rent Lease & Ejectment442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party Act/Review or Appeal of
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 Agency Decision
’ 245 Tort Product Liability Accommodations ’ 530 General ’ 950 Constitutionality of
’ ’
290 All Other Real Property ’ 535 Death Penalty
445 Amer. w/Disabilities - IMMIGRATION State Statutes
Employment Other: ’ 462 Naturalization Application
’ ’ 540 Mandamus & Other
446 Amer. w/Disabilities - ’ 465 Other Immigration
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’1 Original ’2 Removed from ’ 3 Remanded from ’ 4 ’
Reinstated or ’
5 Transferred from 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
28 U.S.C. Section 1332(a)
VI. CAUSE OF ACTION Brief description of cause:
Suit to invalidate lien on Property.
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
09/24/2020 /s/ Robert T. Mowrey
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
JS 44 Reverse (Rev. 06/17) - TXND (Rev. 06/17)
Case 4:20-cv-01057-P Document 1-2 Filed 09/24/20 Page 3 of 3 PageID 13
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court.
This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet.
Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed.
The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants.Enter names (last, first, middle initial) of plaintiff and defendant.
If the plaintiff or defendant is a government agency,
use only the full name or standard abbreviations.
If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at
the time of filing.
In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing.
(NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record.
If there are several attorneys, list them on an attachment,
noting in this section "(see attachment)".

II. Jurisdiction.The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings.
Place an
"X" in one of the boxes.
If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff.
(1) Jurisdiction based on 28 U.S.C. 1345 and 1348.
Suits by agencies and officers of the United States are included here.
United States defendant.
(2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question.(3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States.
In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship.
(4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states.
When Box 4 is checked, the
(See Section III below; NOTE: federal question actions take precedence over diversity
citizenship of the different parties must be checked.
cases.)

III. Residence (citizenship) of Principal Parties.
This section of the JS 44 is to be completed if diversity of citizenship was indicated above.
Mark
this section for each principal party.

IV. Nature of Suit.Place an "X" in the appropriate box.
If there are multiple nature of suit codes associated with the case, pick the nature of suit
code that is most applicable.
Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.
Original Proceedings.(1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action.
Use the date of remand as the filing
date.
Reinstated or Reopened.(4) Check this box for cases reinstated or reopened in the district court.
Use the reopening date as the filing date.
Transferred from Another District.
(5) For cases transferred under Title 28 U.S.C. Section 1404(a).
Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer.
(6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File.
(8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.

VI. Cause of Action. Do not cite
Report the civil statute directly related to the cause of action and give a brief description of the cause.
jurisdictional statutes unless diversity.
Example: U.S. Civil Statute: 47 USC 553Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action.Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any.
If a related case exists, whether pending or closed,
insert the docket numbers and the corresponding judge names for such cases. A case is related to this filing if the case: 1) involves some or all of the
same parties and is based on the same or similar claim; 2) involves the same property, transaction, or event; 3) involves substantially similar issues of
law and fact; and/or 4) involves the same estate in a bankruptcy appeal.

Date and Attorney Signature. Date and sign the civil cover sheet.
Case 4:20-cv-01057-P Document 1-3 Filed 09/24/20 Page 1 of 3 PageID 14

Exhibit B-1
Case 4:20-cv-01057-P Document 1-3 Filed 09/24/20 Page 2 of 3 PageID 15
Supplemental Civil Cover Sheet
Page 1 of 2

Supplemental Civil Cover Sheet for Cases Removed
From State Court

This form must be attached to the Civil Cover Sheet at the time the case is filed in the U.S. District
Clerk’s Office. Additional sheets may be used as necessary.

1. State Court Information:

Please identify the court from which the case is being removed and specify the number assigned
to the case in that court.

Court Case Number
348th Judicial District Court, Tarrant County, Texas 348-318654-20

2. Style of the Case:

Please include all Plaintiff(s), Defendant(s), Intervenor(s), Counterclaimant(s), Crossclaimant(s)
and Third Party Claimant(s) still remaining in the case and indicate their party type. Also, please
list the attorney(s) of record for each party named and include their bar number, firm name,
correct mailing address, and phone number (including area code).

Party and Party Type Attorney(s)
Plaintiff; Tony Hoa Lam Kent Canada
Defendant, Wells Fargo Bank, N.A. Robert T. Mowrey, Matthew H. Davis &
Jennifer McCammon

3. Jury Demand:

Was a Jury Demand made in State Court? Yes ✔ No
If “Yes,” by which party and on what date?

___________________________________ ______________________
Party Date
Case 4:20-cv-01057-P Document 1-3 Filed 09/24/20 Page 3 of 3 PageID 16
Supplemental Civil Cover Sheet
Page 2 of 2

4. Answer:

Was an Answer made in State Court? ✔ Yes No
If “Yes,” by which party and on what date?

___________________________________
Defendant, Wells Fargo Bank, N.A. ______________________
09/11/2020
Party Date

5. Unserved Parties:

The following parties have not been served at the time this case was removed:

Party Reason(s) for No Service

6. Nonsuited, Dismissed or Terminated Parties:

Please indicate any changes from the style on the State Court papers and the reason for that
change:

Party Reason

7. Claims of the Parties:

The filing party submits the following summary of the remaining claims of each party in this
litigation:

Party Claim(s)
Plaintiff Declaratory judgment; seeking to invalidate Note and Deed of
Trust lien because the statute of limitations has expired.
Case 4:20-cv-01057-P Document 1-4 Filed 09/24/20 Page 1 of 3 PageID 17

Exhibit C
Case 4:20-cv-01057-P Document 1-4 Filed 09/24/20 Page 2 of 3 PageID 18
Case 4:20-cv-01057-P Document 1-4 Filed 09/24/20 Page 3 of 3 PageID 19
Case 4:20-cv-01057-P Document 1-5 Filed 09/24/20 Page 1 of 7 PageID 20

Exhibit C-1
Case 4:20-cv-01057-P Document 1-5 Filed 09/24/20 Page 2 of 7 PageID 21 Gm
FILED
TARRANT COUNTY
348-318654-20 8/14/2020 12:14 PM
THOMAS A. WILDER
No. DISTRICT CLERK

TONY HOA LA1VI, IN THE
Plaintiff,

V. COUNTY OF TARRANT

WELLS FARGO BANK, NA,
Defendant. STATE OF TEXAS

ORIGINAL PETITION
FOR DECLARATORY JUDGMENT

TO THE HONORABLE JUDGE OF SAID COURT:

Tony Hoa Lam, an individual, for his petition against WELLS FARGO BANK, NA,

respectfully shows the Court:

I. Discovery Level

i.oi This matter should be governed b

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Exhibit,Appendix: TONY HOA LAM| VS | WELLS FARGO BANK, NA

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Exhibit,Appendix: TONY HOA LAM| VS | WELLS FARGO BANK, NA

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