XX/XX/2017 The XXXX Department of XXXX XXXX XXXX, CA XXXX XXXX, XXXX XXXX XXXX, CA XXXX Law Office of XXXX XXXX XXXX, CA XXXX Re : Loan Number XXXX Subject : Notice of Error, Request for Documents, Wrongful Foreclosure, and Authorization Lender : Reverse Mortgage Solutions, dba XXXX ID : XXXX Trustee Sale Number : XXXX Case Number : XXXX Borrower : XXXX Property Address : XXXX XXXX, CA XXXX Attention : XXXX Department of XXXX XXXX ( XXXX ) is currently assisting the above referenced client to review a legal matter. Please accept this letter of representation regarding our client XXXX. 

The XXXX is reaching out to your office in an attempt to resolve a wrongful foreclosure action against my, XXXX. XXXX has a reverse mortgage with Reverse Mortgage Solutions ( RMS ). 

As part of scheduled repairs, my client initiated and completed repairs on her home. My client provided all of the required documents which confirmed that all repairs had been completed. Unfortunately, our review confirmed that RMS negligently failed to act reasonably to postpone and or cancel a pending foreclosure action on my client 's property. Subsequently, my client 's home was sold at trustee sale to a third party ( XXXX XX/XX/XXXX, XXXX ). 

Following the sale, RMS representatives acknowledged their error, and provided assurance that the issue would be resolved. My client was served with an Unlawful Detainer action, continually harassed to vacate or surrender her property, and threatened with legal action by the new owner. RMS has failed to resolve this issue in a timely manner, and has failed to respond to numerous requests for information. 

A review of my client 's records confirmed that my client initiated required repairs to her property in compliance with the Promissory Note and Deed of Trust executed at the time her loan was originated. 

Please note, my client is elderly and has limited mobility. This factor caused a delay in initiating repairs to the property. Further, the required repairs were limited to minor replacement of carpet in two rooms. Also, my client was in constant contact with the lender during this entire process and provided necessary updates to the lender, as the repairs were being ordered and completed. 

On or before XX/XX/XXXX my client provided RMS a work invoice from XXXX. XXXX, which confirmed the completion on the required repairs at the property referenced above. On XX/XX/XXXX, my client spoke with XXXX, a representative at RMS which dealt with this repair issue. On this date XXXX confirmed that she would be postponing and or cancelling the pending foreclosure sale scheduled for XX/XX/XXXX. 

On XX/XX/XXXX, my client faxed RMS proof of completion from XXXX. XXXX. My client followed up with a telephone conversation, again, with XXXX, who again assured her that the foreclosure sale date was in the process of being cancelled or postponed. 

On XX/XX/XXXX, inspectors from RMS completed their physical review of the property and repairs and confirmed that all work had been completed on the property. On this same day, my client spoke with a RMS representative to confirm the inspection was complete and confirm that the foreclosure sale had been cancelled. The RMS representative assured my client that no foreclosure action would be completed. On the following day, my client once again spoke with RMS and was reassured that no sale would be completed. 

On XX/XX/XXXX, having failed to cancel or delay the fore