I believe the easiest way to explain what has happened is to copy and paste my response to the summons I received regarding Pacific Union 's intent to foreclose on my property : XX/XX/XXXX Re : Case # XXXX Response to Plaintiffs Claim in re : Case # XXXX In the case of Pacific Union v.,  known as Case # XXXX, please consider this my official response in regard to the claims made by the defendant. 

1 ) On XX/XX/XXXX, I began the official process of requesting a loan modification from Pacific Union. This request was in guidelines for receiving a loan modification from Pacific Union and from XXXX XXXX as the request was 2 years past the original loan modification as indicated by Pacific Union in the complaint. This request was submitted electronically and confirmed received by Pacific Union. 

2 ) Between XX/XX/XXXX and the month of XX/XX/XXXX, I was repeatedly asked to resend information in which Pacific Union had already confirmed electronically received. Subsequent conversations and electronic communication verifies this, as well as written requests from Pacific Union. Additionally, Pacific Union had asked for proof of my bankruptcy discharge, which was also sent. 

3 ) All requests made by Pacific Union were met by me within their allotted time frame. I received confirmation from Pacific Union that all documentation had been met and that a loan modification was in process. I was told that the modification was within the Underwriters approval and that I would hear from them shortly in regards to the terms of the modification. 

4 ) Months passed and I had kept in constant electronic communication, as well as phone calls with various retention specialists as to the progress of my modification. I was constantly told that it was still within the review process. 

5 ) After multiple attempts to determine the status of my modification, I resubmitted the entire package on XX/XX/XXXX. 

6 ) In a letter received from Pacific Union dated XX/XX/XXXX they had requested additional information to be received within 14 days of their letter. On XX/XX/XXXX I sent the additional information as requested within the time frame of their request. 



7 ) In an additional letter received from Pacific Union dated XX/XX/XXXX, Pacific Union requested additional information. It is of note that their letter is dated XX/XX/XXXX and that it was received a full two weeks later after the date of the letter and that within the framework of their letter they state that the additional information requested is due on XX/XX/XXXX. Given that the information they requested was already received electronically and confirmed to be received, the fact that they requested information by XX/XX/XXXX and having not even sent the request until their own acknowledged date of XX/XX/XXXX, suggests that there was a willful intent to disqualify me from additional modification assistance. This practice, along with multiple letters with multiple deadline dates also suggests that there was a willful attempt to be misleading, cause confusion, delay the process of modification until they could process a foreclosure against myself and the property. 

8 ) In a letter dated XX/XX/XXXX, Pacific Union indicated that they had received my request, once again, and that they needed additional documentation. This letter included a deadline very specifically of XX/XX/XXXX. As of the date of this summons response, this deadline date has not passed. 

9 ) On XX/XX/XXXX, I sent the documentation, as requested to Pacific Union electronically and received confirmation that it had been received by Pacific Union. 

10 ) On XX/XX/XXXX, I received a certified letter from Pacific Union stating that they are now suing me for the mortgage balance. This date is noteworthy in that Pacific Union has stated unequivocally in their own letter as referenced in Item # 8 that I had until XX/XX/XXXX to comply with their additional request of information. 

11 ) To date, I have not received any confirmation or denial officially of either of my loan modification requests. As to my knowledge, the first request, made back in XX/XX/XXXX may even still be within the Underwriting Department awaiting official approval or denial. 



It is in my opinion that Pacific Union has shown a willful and malicious intent to confuse, delay and ultimately deny any and all attempts by me to gain a mortgage modification which would allow me to retain occupancy of the property and to alleviate any back due mortgage payments, interests and lawyer fees. 

It is also my opinion that Pacific Union may be in violation of the Federal Law which prohibits Dual Tracking. 

I am asking that the court suspend any further foreclosure proceedings by Pacific Union Financial until a settlement conference can take place between myself and Pacific Union Financial. I will officially request a settlement conference of the court with my next correspondence. 

It is also my intent to pursue legal action and retain legal counsel against Pacific Union and to possibly file a suit in regards to Dual Tracking and Unfair Competition as allowed by Indiana Law. 

I also intend to submit a formal complaint to the Consumer Financial Protection Bureau in regards to what I feel is a violation of the Dodd-Frank Act.