Exhibit 1

Case 4:22-cv-00772-O Document 1-1 Filed 08/29/22 Page 1 of 2 PageID 14
MACKIE WOLF ZIENTZ & MANN, P.C. 

ATTORNEYS AT LAW 

PHONE (214) 635-2650 FAX (214) 635-2686 

PARKWAY OFFICE CENTER, SUITE 900 

14160 NORTH DALLAS PARKWAY 

DALLAS, TEXAS 75254 

* PLEASE RESPOND TO DALLAS OFFICE 

18-000042-210 

January 18, 2019 

CERTMAlL 

UNION PLAZA 

124 WEST CAPITOL, SUITE 1560 

LITTLE ROCK, ARKANSAS 72201 

JOANN H. MEANS, ATTORNEY FOR APPLICANT JEFFREY RAY GROOMS 

4200 SOUTH HULEN STREET, SUITE 680 

FORT WORTH, TX 76109 

RE: Loan No.: XXXXXX2275 

MWZM File No.: 18-000042-210-1 

NOTICE OF DEFAULT AND INTENT TO ACCELERATE 

Dear JOANN H. MEANS, ATTORNEY FOR APPLICANT JEFFREY RAY GROOMS: 

We have been retained by CELINK, Mortgage Servicer for BANK OF NEW YORK MELLON TRUST COMPANY, 

N.A. AS TRUSTEE FOR MORTGAGE ASSETS MANAGEMENT SERlES I TRUST, the current Mortgagee of the 

Note and Texas Home Equity Conversion Deed of Trust related to the above referenced loan. A servicing agreement 

between the Mortgagee, whose address is: 

BANK OF NEW YORK MELLON TRUST COMPANY, N.A. AS TRUSTEE FOR MORTGAGE ASSETS 

MANAGEMENT SERlES I TRUST 

c/o CELINK 

2900 ESPERANZA CROSSING 

AUSTIN, TX 78758 

and the Mortgage Servicer authorizes the Mortgage Servicer to collect the debt. 

You are hereby advised that a default exists under the terms and conditions of the Reverse Mortgage in that the grantor 

of the Reverse Mortgage passed away. Demand is hereby made for payment in full of the balance owed. According to 

the Mortgage Servicer's records, the total balance due as of the date of this notice is $83,759.93. As a result of accrued 

interest and other charges, the total balance due may be greater on the date of your payment and an adjustment may be 

required to fully reinstate the loan. You may obtain the precise amount due by contacting this firm at (214) 635-2650. 

Payment must be made by cashier's check, certified check or money orders. 

You are hereby notified that if the Reverse Mortgage is not paid in full within thirty (30) days of the date of this notice, 

the Mortgage Servicer will thereafter accelerate the maturity date of the Note, and commence in scheduling a 

foreclosure sale of the property according to the terms of the Reverse Mortgage, Tex. Const. art. XVI § 50(k)(6)(A) and 

Texas Property Code §51.0025. 

Federal law allows you to dispute the validity of the debt, or any portion thereof, within thirty days (30) after receipt of 

this notice. If you do not, the debt will be assumed valid by the firm. If you notify the firm in writing within thirty 

days of receipt of this letter that the debt or any portion of the debt is disputed, the firm will obtain verification of the 

debt and will mail a copy of the verification to you. On your written request, within the thirty-day period for 

verification, the firm will provide you with the name and address of the original creditor. Additionally, all of the 

obligors and guarantors (if any) have the right to bring a court action to assert the non-existence of a default or any 

other defense which they may have. 

If this debt has been discharged in bankruptcy or you are not obligated on this debt, the Mortgage Servicer is not 

attempting to collect this debt from you personally. 

ASSERT AND PROTECT YOUR RIGHTS AS A MEMBER OF THE ARMED FORCES OF THE UNITED 

STATES. IF YOU ARE OR YOUR SPOUSE IS SERVING ON ACTIVE MILITARY DUTY. INCLUDING 

ACTIVE MILITARY DUTY AS A MEMBER OF THE TEXAS NATIONAL GUARD OR THE NATIONAL 

GUARD OF ANOTHER STATE OR AS A MEMBER OF A RESERVE COMPONENT OF THE ARMED 

FORCES OF THE UNITED STATES, PLEASE SEND WRITTEN NOTICE OF THE ACTIVE DUTY 

MILITARY SERVICE TO THE SENDER OF THIS NOTICE IMMEDIATELY. 

THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT THE DEBT AND ANY 

INFORMATION OBTAINED BY IT WILL BE USED FOR THAT PURPOSE. 

Sincerely yours, 

Mackie Wolf Zientz & Mann, P.C. 

Case 4:22-cv-00772-O Document 1-1 Filed 08/29/22 Page 2 of 2 PageID 15