DEFENDANTS DHI MORTGAGE COMPANY’S AND DHI TITLE’S BRIEF IN SUPPORT OF MOTION TO DISMISS PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

TIANIKWA HAYWOOD and PAUL 

DOUGLAS CELESTINE,

Plaintiffs,

vs.

TEXAS REALATOR, CEO OR OWNER,

MACKIE WOLF ZIENTZ & MAN, P.C. 

LAW FIRM, STANFORD & KURLAND, 

OWNER OF PENNYMAC LOAN 

SERVICES, LLC; SONYA 

LUECHAUSER, CEO & PRESIDENT,

DHI MORTGAGE COMPANY, LTD, TIM 

NICHOLSON, VICE PRESIDENT 

PENNYMAC LOAN, SANDRA NASEEF

DHS TITLE CO., JOHN DOE, JANE DOE

Defendants.

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Civil Action No. 3:22-cv-2174-C

DEFENDANTS DHI MORTGAGE COMPANY

and DHI TITLE’S BRIEF IN SUPPORT OF MOTION TO DISMISS

Defendant DHI Mortgage Company, Ltd. (“DHIM”), and DHI Title (“DHIT”) file this 

Brief in Support of their Motion to Dismiss, under Federal Rule of Procedure 12(b)(6), all 

claims asserted against them in this action filed by Plaintiffs. Plaintiffs’ claims as set 

forth in the Complaint fail to state any claim for relief against DHIM or DHIT.

1

A. The Claims in the Lawsuit are unintelligible.

In the Lawsuit, Plaintiffs allege all Defendants violated what Plaintiffs call “FalseCommunication-Sentence-Parse Syntax-Grammar, or F.C.S.S.P.S.G.” According to the 

Lawsuit, the alleged violation of the F.C.S.S.P.S.G is “by the grammar and the framing 

or boxing of the loan agreement under Maritime law.”

1 Plaintiffs live pleading is titled a “Lawsuit” but will be referred to herein as a Complaint.

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DEFENDANTS DHI MORTGAGE COMPANY’S AND DHI TITLE’S BRIEF IN SUPPORT OF MOTION TO DISMISS PAGE 2

The lawsuit is made up of other assertions that also do not have any legal or realworld meaning:

“Both the lender and borrower, thus, fraud being fraud in nature and by all of the 

Defendants working together to complete the conspiracy of Title 18 U.S.C. 1961-

1968 Rico Act, that by the Defendant’s conduct there was no bank sign of the 

fraudulent mortgage contract.”

“The Plaintiff invokes now time under Maritime Law, in which, truth and facts shall 

come before the court. The Plaintiffs have paid the fee to move the vessel out of 

dry dock into the sea of space. This claim is being filed for the Defendants' use of 

fraudulent grammar in the contracts and loan agreement by the fraud of the 

Defendants.”

“For the claimant's knowledge of facts of the claim of law, rules, codes, and 

regulation with the C.S.S.C.P.S.G. of this court, the complete request by the 

Defendants own knowledge that the contract is void by the violation of 

C.S.S.C.P.S.G.”

“Thus, for the harm caused by the Defendants the Plaintiff is suing for 

$50,000,000.00 USD (Fifty million dollars). The post Office is over every vessel in 

the United States of America and this honorable court has jurisdiction.”

“The Defendants have continued the fraud by the letters from Texas Realtor that 

F.P.S.G. thus, the Plaintiff under the protection of due process of law under the 

14th Amendment is requesting that the C.S.S.C.P.S.G. as required under 

Maritime Law.”

B. No claim for relief is stated.

Plaintiffs have not asserted any viable causes of action against DHIM or DHIT, 

nor have they asserted any claims that could entitle them to any of the relief sought. 

There is no basis in law or fact to support any claims against DHIM or DHIT. The only 

“cause of action” that appears to have been pled is a violation of “False-CommunicationSentence-Parse Syntax-Grammar, or F.C.S.S.P.S.G.,” which is not a recognized or 

viable legal claim.

Plaintiffs do not plead facts that could support any relief sought against DHIM or 

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DEFENDANTS DHI MORTGAGE COMPANY’S AND DHI TITLE’S BRIEF IN SUPPORT OF MOTION TO DISMISS PAGE 3

DHIT under any legal theory. DHIM and DHIT move to dismiss all claims against them. 

The suit must be dismissed because Plaintiffs fail to state any claim upon which relief 

can be granted. To survive a motion to dismiss under Rule 12(b)(6), a complaint must 

contain more than “labels and conclusions” or a “formulaic recitation of the elements of a 

cause of action.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. 

Twombly, 550 U.S. 544, 555 (2007)). Rather, the complaint must include “sufficient 

factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Id. 

(internal quotations and citations omitted). “A claim has facial plausibility when the 

plaintiff pleads factual content that allows the court to draw the reasonable inference 

that the defendant is liable for the misconduct alleged.” Id. (citation omitted).

Plaintiffs’ pleading does not allege any specific actions by DHIM or DHIT 

sufficient to state a claim against them for any alleged violations of the law. The Lawsuit 

does not articulate any well-pleaded facts rationally supportive of any claim against 

DHIM or DHIT.

C. CONCLUSION

This case should be dismissed as to DHI Mortgage Company, Ltd. and DHI Title.

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DEFENDANTS DHI MORTGAGE COMPANY’S AND DHI TITLE’S BRIEF IN SUPPORT OF MOTION TO DISMISS PAGE 4

Respectfully submitted,

By: /s/ David M. Kleiman

DAVID M. KLEIMAN

SBN 11555950

dkleiman@wslawpc.com

(214) 979-7400

(214) 979-7402 – Fax 

WADDELL SERAFINO GEARY RECHNER 

JENEVEIN, P.C.

Comerica Bank Tower

1717 Main Street, 25th Floor

Dallas, TX 75201-7341

ATTORNEYS FOR DHI MORTGAGE COMPANY AND 

DHI TITLE

CERTIFICATE OF SERVICE

A true and correct copy of the foregoing has been forwarded to the following pro 

se Plaintiffs via certified mail return receipt requested and to counsel of record by eservice on this the 24th day of October 2022:

Certified Mail, RRR

9489 0090 0027 6403 2964 42

Tianikwa Haywood

Paul Douglas Celestine

3222 Burgundy Lane

Midlothian, TX 76065

/s/ David M. Kleiman

David M. Kleiman

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