Denise Subramaniam 

Self-represented 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

FILED18 ._TIJ..I '1514:57usre~ 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

LNV CORPORATION 

Plaintiff, 

v. 

DENISE SUBRAMANIAM 

pro per 

Defendant 

Civil Case No. 3:14-cv-01836 

DEFENDANT'S NOTICE 

OF RELATE CASES 

DEFENDANT'S NOTICE OF DIRECTLY RELATED CASES 

Pursuant to Federal Rule 40.2(a)(l) Defendant files this Notice of Directly Related Cases, and 

respectively shows the court as follows: 

A directly related case existed as Subramaniam v. Beal et al, Case No. 3:12-cv-01681-MO in this 

court stemming from a wrongful foreclosure attempt on Defendant's property in 2012 by 

Plaintiff, LNV Corporation ("LNV"); and Subramaniam v. Beal Case No: 3:2014cv01482. The 

Honorable Judge Michael W. Mosman presided over the first case while the Honorable Judge 

Michael H. Simon presided over the second. Plaintiff knows these are directly related cases 

because it included Defendant's complaints in these two cases as exhibits attached to its 

complaint in the present case. 

Defendant's Notice of Related Case Page 1of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 1 of 17
proceedings of this directly related case; and such violation resulted in the present foreclosure 

action now in this court brought by Plaintiff, LNV against Defendant. 

Additionally this present case is directly related to the following cases which all originate from 

the same transaction and involve the same opposing party. These directly related cases are: 

1. September 2012 - Catherine Gebhardt: LNVCorporation v. Gebhardt. Case No. 3:12-

CV-468-TA V-HBG, U.S. District Court Eastern District of Tennessee at Knoxville. 

2. Tuli Molina Wohl: LNV Corporation v. Tuli Molina Wohl. Case No. 1 CA-CV 11-0603, 

In the Court of Appeals, State of Arizona Division One 

3. 2013 -Robynne A. Fauley: Fauley v. Washington Mutual et al (LNV). Case No. 3:13-cv00581-AC, U.S. District Court District of Oregon, Portland Division; and LNV v. Fauley; 

Case No. CVJ 5040532: Clackamas County 

4 .. June 2, 2011 - Christopher and Marcia Swift: In the United States Bankruptcy Court for 

the Northern District of/llinios, Eastern Division; Case No. 12-35690 (LNV Corp v 

Swifts 2011-ch-00206; Circuit Court of] 61

h Judical Kane Counnty fllinios LNV Corp v 

Swifts 

5. 2010-2013 -Rhonda L. Hardwick: LNVas assignee o[MERS Inc. as nominee for First 

Capital Finaicial Services Corp. DBA Full Compass Lending v. Hardwick, Case No. 

51COJ-1204-MF-00098; State oflndiana County of Martin in the Martin Circuit Court 

Each of these cases arise from the same financial transaction between either MERS as an agent 

or a GMAC related entity and LNV Corporation, in all these cases LNV produced and submitted 

to a court as genuine an allonge to the note purportedly endorsed by Jason J. Vecchio a GMACRFC employee. In each of these cases LNV produced and submitted to a court as genuine an 

assignment of deed of trust purporting to convey beneficial interest to LNV; and these 

assignments of deed of trust are purportedly signed by GMAC-RFC employees Michael Mead or 

Betty Wright and notarized by GMAC-RFC employee Diane Meistad; and each was executed on 

March 10, 2008; seven days prior to the incorporation ofLNV in Nevada. March 10, 2008 also 

coincides with the date that commenced the demise of Bear Steams. 

Defendant's Notice of Related Case Page 2of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 2 of 17
Defendant spoke on the phone with Diane Meistad who confirmed these assignments of deed of 

trust were all produced as part of a single financial transaction with LNV in 2008 that included 

numerous loan packages. She also confirmed she was an employee of GMAC's Residential 

Funding Company, LLC fka Residential Funding Corp. ("GMAC-RFC") and that Michael Mead 

and Betty Wright were also employees of GMAC-RFC and that they signed documents related to 

this very large transaction throughout many weeks. 

The Jason J. Vecchio signatures on the allonges in each of these cases are identical. A 

preliminary examination of four of these Jason J. Vecchio signatures and a report by OMNI 

Document Examinations ("OMNI") dated December 4, 2014 shows that after an examination of 

these allonges OMNI determined that the signatures of Jason J. Vecchio "submitted as genuine ... 

were stamped signatures or photocopied signatures." In order to definitively determine whether 

one of the signatures are genuine or if all are copies the original notes and allonges must be 

produced for examination. This preliminary report casts doubt on the genuineness of the LNV 

produced "original" notes in all the related cases. 

Furthermore, LNV through their attorneys at Lender Processing Services aka Black Knight 

Financial Services ("LPS") affiliated Anselmo Lindberg Oliver LLC fka Freedman Anselmo 

Lindberg LLC, showed Marcia and Chris Swift what LNV alleged was their "original" note. 

Defendant went with Robynne A. Pauley to the law offices of LPS affiliated RCO Legal in 

Portland to examine what LNV alleged was her "original" note. Viewings of these two alleged 

"original" notes revealed similar characteristics that identify them as forgeries. 

This present case is also directly related to the case: Breitlings v. LNV et al; Case No. 3: 15-CV00703; U.S. District Court for the Northern District of Texas Dallas Division. The Breitlings' 

Defendant's Notice of Related Case Page3of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 3 of 17
case (and their many related the cases including: Breitlings v. LNV; Case No. 314-cv-03322 U.S. 

District Court for the Northern District of Texas Dallas Division; LNV v. Breitlings; Case No. 

DC-14-04053 in the Dallas Civil District Court of Texas; LNV v. Breitlings and all other 

Occupants, Case No. JE-150007 lD, in the Justice of the Peace Court No. 2 Dallas County 

Garland Texas; LNV v. Breitlings and all other occupants. Case No. CC-15-00911-C Dallas 

County Court of Law, Court No. 3; Breitlings v. Ames and MGC. Case No. DC-10-02189 in the 

Dallas Civil District Court of Texas; and Breitlings v. MGC. Case No. DC-11-07087 in the 

Dallas Civil District Court of Texas) is directly related to the present case because it involves the 

same party, LNV, and similar claims. 

The Breitlings, like the other Beal victims named above, have experienced numerous instances 

of mortgage servicing fraud from LNV's alleged mortgage servicer, MGC Mortgage Inc. 

("MGC"). Both LNV and MGC are privately owned and operated by Daniel Andrew "Andy" 

Beal. The parties named herein opposing Beal' s LNV in all these related cases are victims of 

multiple instances of crimes that constitute a pattern of criminal activity perpetrated on them by 

D. Andrew Beal and his corrupt business organization and his agents and attorneys that include 

but are not limited to: financial fraud, forgery, unlawful debt collection, theft of property, 

conspiracy to commit fraud, abuse of judicial process, fraud upon the court, improper influence, 

coercion, intimidation, tampering with evidence, and many more acts of bad faith and criminal 

intent extending over many years for purposes of the personal financial gain of Mr. Beal and to 

the detriment of his victims. 

Related party Catherine Gebhardt in Tennessee is about to be wrongfully evicted from her home 

by LNV. Her troubles with Beal's MGC began in 2008 when she mailed a cashier's check made 

Defendant's Notice of Related Case Page 4of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 4 of 17
payable to MGC to 7195 Dallas Parkway, Plano Texas for $6,000 to be applied to her mortgage 

to cover three months of payments. MGC claimed they never received that check, but when Ms. 

Gebhardt was finally able to retrieve this check from her bank it shows the check was paid to 

Beal Bank SSB on October 29, 2008. This was not the only payment MGC misappropriated and 

Ms. Gebhardt complained to every government agency she could think of including her 

Congressman because MGC refused to resolve the continuing problems with misappropriation of 

her payments and was determined to move ahead with foreclosure based on its own trumped up 

default. MGC's Erica Thomas wrote a letter dated June 23, 2011 to Ms. Gebhardt's 

Congressman Roe's office where on page 2 paragraph 2 she states: "MGC has received no 

payments since we acquired serving of the loan from GMAC Mortgage on or around July 1, 

2009." This statement is conclusively false because Beal Bank SSB cashed Ms. Gebhardt's 

$6,000 check on October 29, 2008. (See Exhibit A attached hereto) Many other false statements 

exist in the Erica Thomas letter. She also fails to identify herself as an attorney in this letter. 

Her Texas Bar# is 24042027. It appears from online evidence that Erica Thomas was not 

actually on the payroll with MGC but employed via contract, most likely with Beal Bank. Erica 

Thomas's one big lie in her aforementioned letter is demonstrative ofBeal's pattern of criminal 

activity; especially when considered alongside a sampling of numerous consumer complaint 

letters received by the Texas Attorney General's office describing the same pattern of criminal 

activity. (See Exhibit B) 

Beal victims, including Defendant, made numerous phone calls to IRS agents over a period of 

months and it appears MGC does not have an IRS EIN number; i.e. it cannot have employees. 

Beal victims have requested canceled checks made payable to MGC from their banks and every 

retrieved check was paid to an entity other than MGC, this indicates that MGC does not have its 

Defendant's Notice of Related Case Pages of 16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 5 of 17
own bank account, which also indicates that it does not have an IRS EIN number because one is 

required for a business bank account. This begs the question, why would a mortgage servicing 

company not have an IRS EIN number? The most logical answer is that it doesn't want to report 

its earnings to the IRS and it's a shell corporation used to launder financial transactions. This 

conclusion is supported by the fact that most of the Beal victims experience the exact same 

problems with MGC misappropriating their payments and then using its self-made default to 

foreclose on their properties using falsely fabricated and forged assignments of deed of trust, 

allonges to the note, and forged notes. An examination of Beal victims IRS 1098 forms shows 

that Beal's MGC and its LPS agent Dovenmuehle Mortgage Inc. ("DMI") appear to be falsely 

under reporting the interest paid by Beal victims; Beal victims suspect that Beal falsely reports 

losses to the IRS and other government agencies then launders overseas the excessive profits he 

actually makes through his covert criminal activities that result in wrongful foreclosures on 

thousands of properties across the county. Defendant wrote to the Illinois Attorney Registration 

and Disciplinary Commission about DMI attorney Charles King and the phone call to Tennessee 

State Bank where Charles King used caller-ID spoofing and misrepresented himself as a 

government employee to inquire about a fed-wire transaction made by Ms. Gebhardt into a Bank 

of America account as per MGC's instructions in a payoff letter sent to her and other Beal 

victims. This Bank of America fed-wire account is a legacy global account with DMI as the 

domestic intermediary to an undisclosed overseas recipient. Beal's discovery of this letter 

through its being attached to legal pleadings filed on July 30, 2014 in the LNV v. Breitlings; Case 

No. DC-14-04053 prompted Mr. Beal's surveillance of Defendant beginning on July 30, 2014. 

Unfortunately the courts tend to believe organizations like MGC and LNV instead of examining 

the evidence presented by Beal victims who have mostly ended up representing themselves after 

Defendant's Notice of Related Case Page 6of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 6 of 17
being financially drained by Beal's malicious litigation over many years and/or because their 

own attorneys suspiciously began to sabotage their cases against them in favor of LNV. This 

happened to Ms. Gebhardt; it also happened to the Breitlings and the Swifts. Sudden attorney 

incompetence appears to be another pattern in Beal related cases. The parties opposing Beal' s 

LNV in all these related cases are now all self-represented (and not by choice). 

In LNV v. Breitlings; Case No. DC-I 4-04053 LNV named GMAC as a defendant. This is 

indicative that LNV (i.e. Mr. Beal) had reason to believe GMAC may have a claim of beneficial 

interest in the Breitlings' note and deed of trust. Wilshire was the last mortgage servicer the 

Breitlings made payments to prior to Beal's MGC. Attached to this Notice as Exhibit C is a 

copy of a limited power of attorney executed by Residential Funding Real Estate Holdings LLC 

as "Owner" appointing as attorney-in-fact Wilshire Credit Corporation authorizing Wilshire to 

execute certain documents and transactions for Residential Funding Real Estate Holdings LLC 

which is endorsed with signatures of GMAC-RFC employees Jason J. Vecchio, Betty Wright, 

Barbara Zahn and Steven Hanson and notarized by Mary E. Lueth. This indicates the transaction 

through which LNV acquired the purported assignment of the Breitlings' deed of trust and the 

purported conveyance of their note may have been within one of the packages included in the 

very large deal that Diane Meistad told Defendant about in their phone conversation. Both 

Defendant and Beal victims JoAnn and Samuel Breitling originally financed their property with 

Norwest. Those mortgages were paid in full but Norwest failed to file a satisfaction of mortgage 

in both these cases. LNV included as an exhibit to their complaint in LNV v. Breitlings: Case 

No. DC-14-04053 documents showing that GMAC purchased Norwest. 

Defendant's Notice of Related Case Page 7of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 7 of 17
Additionally LNV showed to WF AA investigative reporter Brett Shipp what Beal alleged to be 

the Breitlings' "original" note which contained characteristics that identify it as a forgery similar 

to those characteristics identifying the aforementioned alleged Swift and Pauley "original" notes 

as forgeries. (Interestingly, Beal refused to allow the Breitlings to view their purported 

"original" note.) 

Cases directly related to the present case are not limited to the ones noticed herein; amendments 

to these Notices of Related Cases or additional Notices of Related Cases will be submitted as 

appropriate. 

Defendant and the other Beal victims have a common law and constitutional right to challenge 

LNV's evidence presented to the court against them, especially when LNV has the burden of 

proof and the result of this ligation/trial will be deprivation of these related parties' property. 

Certainly the respective courts in these related cases would not want to be party to the derivation 

of constitutional rights and/or party to a conspiracy to defraud these related parties' and thereby 

wrongfully deprive them of their properties. 

This matter is of outmost public interest to any American citizen who owns property as there can 

be no public confidence in a judiciary that appears so biased towards financial institutions (and 

the Beal entities are not truly financial institutions but shams designed to appear to be something 

they not) that it trashes the constitutional rights of American homeowners and refuses to 

acknowledge a preponderance of evidence that shows the Beal entities have submitted forged 

documents to the courts and made false claims to the courts about their standing to foreclose on 

the Beal victims properties; and that their claims of default are also fabricated and the result of 

their own misdeeds and intentional misappropriation of their victims payments. If the respective 

Defendant's Notice of Related Case Page 8of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 8 of 17
courts hearing these related cases allow the Beal entities to get away with this blatant pattern of 

criminal activity then no American homeowner is safe from a similar unwarranted and 

unconstitutional court sanctioned criminal derivation of their property by any party who claims 

to have standing and the capacity to forge the appropriate documents to make it appears that they 

do when they do not. (All it takes to forge documents that look genuine is a computer and Adobe 

Photoshop software.) 

Pursuant to RCFC 42.1and18 U.S. Code§ 3663A the parties opposing Beal's LNV in these 

related cases motion the courts presiding over these related cases for consolidation of these 

related cases for the limited purposes of compelling Beal and his LNV to produce the alleged 

"original" Swift, Hardwick, Pauley and Breitling notes already shown to the Swifts, to Robynne 

A. Pauley and Denise Subramaniam, and to Brett Shipp, (and which all possess characteristics 

that identify them as forgeries), in addition to the original notes for Tuli Molina Wohl, Rhonda 

L. Hardwick, Catherine Gebhardt and Denise Subramaniam; and to tum these alleged "original" 

notes over to the custody of the United States Bankruptcy Court For the Northern District of 

Illinois Eastern Division and into the custody and care of Judge Donald R. Cassling and/or the 

United States Attorney General, Lorretta Lynch, via the office at the Northern District of Illinois, 

Eastern Division, 219 S. Dearborn St., 5th Floor, Chicago, IL 60604 for the purposes of forensic 

evaluation for authenticity by OMNI Document Examinations and Robin D. Williams at 205 W. 

Wacker Drive, Suite 922, Chicago, IL 60606 and for purposes of further examination by the 

United States as appropriate; and for purposes of deposing Robin D. Williams after examination 

of these notes is complete so that his expert testimony as well as his report can be submitted as 

expert testimony in each of the related cases. 

Defendant's Notice of Related Case Page 9of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 9 of 17
In addition to these notes the parties opposing Beal' s LNV in these related cases seek 

examination of all documents relative to the transaction(s) and contract between GMAC-RFC 

and/or other parties and LNV that gives rise to LNV's claim of conveyance and/or assignment(s) 

of the aforementioned notes and deeds of trust; all documents and contracts specific to the 

business relationship(s) between LNV and MGC; between LNV and/or MGC and Dovenmuehle 

Mortgage Inc.; and between LNV and/or MGC and any and all Lender Processing Services 

("LPS") aka Black Knight Financial Services affiliated entities; as well as an examination of the 

LPS Desktop Database referred to in the Bret Maloney deposition in the Swift case by an expert 

database examiner and/or the FBI. LNV submitted to courts affidavits of Bret Maloney in 

several of the related cases which these courts relied on as truthful testimony. A comparison 

Bret Maloney's testimony in the aforementioned deposition as well as a deposition in Harris v. 

LNV. Case No. 3:12-CV-0552 in the U.S. District Court for the Middle District of Tennessee, 

Nashville Division, and his many affidavits shows Maloney has committed perjury and his 

testimony should be stricken. This is not just because he claimed to have never committed a 

felony crime and the Beal victims discovered he had and have the criminal records to prove it, 

but because of many inconsistencies with his testimony and statements he made which can be 

proven false; if the Beal victims can ever in truth be heard by a court, (i.e. have meaningful 

access to the judiciary, due process and equal protection of the laws.) 

18 U.S. Code§ 3663A(a) states: 

"Whenever the Attorney General has reason to believe that any person or enterprise 

may be in possession, custody, or control of any documentary materials relevant to a 

racketeering investigation, he may, prior to the institution of a civil or criminal 

proceeding thereon, issue in writing, and cause to be served upon such person, a civil 

investigative demand requiring such person to produce such material for 

examination." 

Defendant's Notice of Related Case Page 10of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 10 of 17
Several of the parties opposing Beal's LNV in these related cases have filed Notices of 

Constitutional Questions and collectively beseech the United States Attorney General to issue 

such a civil investigative demand to Daniel Andrew Beal ("Beal") requiring him to produce the 

aforementioned materials for examination. The parties opposing Beal's LNV in these related 

cases have consistently claimed that they are individually and collectively victims of the crimes 

of convicted felon Lorraine Brown and victims of a corrupt organization operated by Beal and by 

his "racketeering activity" as defined by 18 U.S. Code§ 1961(1)(B) which states: 

" ... 'racketeering activity' means any act which is indictable under any of the following 

provisions of title 18, United States Code: Section 201 (relating to bribery), ... section 

1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1344 (relating 

to financial institution fraud), ... section 1512 (relating to tampering with a witness, 

victim, or an informant), section 1513 (relating to retaliating against a witness, victim, or 

an informant), ... section 1957 (relating to engaging in monetary transactions in property 

derived from specified unlawful activity), ... " 

From the U.S. Attorneys' Criminal Resource Manual section 2173. Jury Instruction -- Criminally 

Derived Property - 18 U.S.C. 1957(t)(2): 

"The term 'criminally derived property' means any property constituting or derived 

from, proceeds obtained from a criminal offense ... This term only requires that the 

property be derived from a criminal offense. There is no definition of criminal offense. 

Thus, there is no obligation that the property be derived from felonious conduct in 

violation of state, federal or foreign law ... Thus, the government must prove only that 

defendant knew that the property involved in the monetary transaction constituted, or 

was derived from, [directly or indirectly], proceeds obtained by some criminal offense. It 

need not prove that he/she knew the precise nature of the criminal offense from which 

the proceeds derived." 

The United States Attorney General already prosecuted and convicted Lorraine Brown (United 

States of America v. Lorraine Brown, Case No. 3:12-cr-198-J-25 MCR, (M.D. Fla.) Lorraine 

Brown was convicted of conspiracy to commit mail and wire fraud pursuant to 18 U.S. Code§ 

Defendant's Notice of Related Case Page 11of16 

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1341 and§ 1343) for the same activities Beal's LNV and MGC and Beal's LPS agents are using 

specific to the parties opposing Beal's LNV in these related cases, i.e. falsely fabricating, forging 

and robo-signing assignments of deed of trust, allonges to notes and affidavits and filing them in 

county recorders offices via mail and wire transmissions; and or filing them with courts across 

the country via mail and wire transmissions. Beal and the business entities within his corrupt 

organization, that include but are not limited to his MGC and LNV, in each of the related cases 

have further used such forged and robo-signed documents to initiate and perfect foreclosures 

knowing this is a violation of numerous Texas (and other states') civil statutes and penal code. 

This is evidenced by a letter sent to his MGC by the Attorney General of Texas dated October 4, 

2010. Beal's MGC responded to the Texas Attorney General's letter in a letter dated October 21, 

2010 by stating that his MGC had assured it was not using such documents in its Texas 

foreclosures. (See Exhibit D for copies of these two letters.) Yet numerous Beal victims 

including the parties opposing Beal's LNV in these related cases (one who resides in Texas) 

claim Beal' s M GC and LNV are doing just that. (In addition to the seven Beal victims whose 

litigation is being related hereby, at least five other Beal victims are from Texas out of an ever 

growing group that now exceeds 40 victims from the additional states of California, Oregon, 

Arizona, North Carolina, New York, New Jersey, Pennsylvania, Ohio, Tennessee, Louisiana, 

Connecticut, Illinois, Indiana and Michigan. The known Beal victims are certain that once 

media reports about Beal thousands if not tens of thousands of Beal victims will come forward; 

and their experiences with the Beal entities within his corrupt organization will be consistent 

with the pattern of criminal activity these seven Beal victims have expressed through their court 

pleadings.) 

Defendant's Notice of Related Case Page 12of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 12 of 17
Many Beal victims claim Beal's MGC misappropriated their payments then used these selfserving misappropriations of their funds to falsely claim they had defaulted on their loans so as 

to justify foreclosure actions where Beal's MGC and LNV then submit to courts as genuine these 

false, forged and robo-signed documents, all the while knowing they are false, with intent to 

deceive the courts and deprive the Beal victims of their property for Beal's personal gain. 

Whether or not the alleged "original" notes and alleged assignments of deed of trust are genuine 

rather than forgeries is material as to whether or not LNV has standing to foreclose on the Beal 

victims' properties. Whether or not Beal's MGC committed intentional servicing fraud by 

misappropriating payments and claiming false defaults against Beal victims so he could 

fraudulently foreclose on their properties is also material as to whether or not LNV has standing 

to foreclose. Likewise these facts are material as to whether or not Beal has committed a pattern 

of felony crimes and engaged in a pattern of criminal activity defined as a pattern of 

"racketeering activity" by 18 U.S. Code§ 1961(1) & (5). Facts specific to whether or not Beal, 

his LNV, his LPS agents and his attorneys and other officers of the court have intentionally 

thwarted justice, tampered with evidence, abused judicial process and engaged in a conspiracy to 

deny the Beal victims their constitutional rights to due process and equal protection of law under 

the fifth and fourteenth amendments are material as to whether or not the Beal victims have been 

unconstitutionally deprived of their property and/or their liberty to make financial decisions 

regarding their property (the largest single investment they have made in their lives); and 

whether or not Beal operates a corrupt organization or "racketeering enterprise" as defined by 18 

U.S. Code § 1961 ( 4). Additionally the aforementioned facts are material as to whether or not 

Beal and his LNV and his agents and/or his attorneys have violated 15 U.S. Code§ 1692 et al. 

Defendant's Notice of Related Case Page 13of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 13 of 17
The Beal victims have suffered significant financial losses and great emotional anguish and 

distress extending over many years as a result of the crimes perpetrated against them by Beal, his 

racketeering enterprise, his LPS agents and his attorneys. 

18 U.S. Code§ 3663A(a)(2) states: 

"For the purposes of this section, the term "victim" means a person directly and 

proximately harmed as a result of the commission of an offense for which restitution 

may be ordered including, in the case of an offense that involves as an element a 

scheme, conspiracy, or pattern of criminal activity, any person directly harmed by the 

defendant's criminal conduct in the course of the scheme, conspiracy, or pattern ... " 

18 U.S. Code§ 3663A(a)(3) states: 

"The court shall also order, if agreed to by the parties in a plea agreement, restitution to 

persons other than the victim of the offense." 

The Beal victims believe Beal should also pay restitution to the United States; specifically to the 

courts due to his pattern of abuse and fraud upon the courts. This restitution should be directly 

used to finance a program to ensure the constitutional rights to due process and equal protection 

of law of parties like the Beal victims are not violated in the future because the courts lack funds. 

18 U.S. Code§ 3663A(b)(l) states: 

"The order of restitution shall require that such defendant in the case of an offense 

resulting in damage to or loss or destruction of property of a victim of the offense (A) 

return the property to the owner of the property or someone designated by the owner; 

or (B) if return of the property under subparagraph (A) is impossible, impracticable, or 

inadequate, pay an amount equal to (i) the greater of (I) the value of the property on 

the date of the damage, loss, or destruction; or (II) the value of the property on the date 

of sentencing, less (ii) the value (as of the date the property is returned) of any part of 

the property that is returned." 

Defendant's Notice of Related Case Page 14of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 14 of 17
In addition to restitution pursuant to 18 U.S. Code§ 3663A et al, (Mandatory Crime Victims 

Restitution Act) victims of Beal's crimes are entitled to damages pursuant to 15 U.S. Code § 

1692 et al, (Fair Debt Collection Practices Act), including damages for emotional distress and 

punitive damages, and to treble damages pursuant to 18 U.S. Code§ 1961 et al. 

A recent decision by the Sixth Circuit Court of Appeals in Case No. 13-3402. Rick Slorp v. 

Lerner, Sampson & Rothfuss, et al Originating Case No.: 2:12-cv-00498 aptly represents the 

interests of the Beal victims in their related cases and the facts to be determined by the courts 

hearing these cases. Quoting from this Appellate decision: 

The district court held that Slorp lacked standing because he sustained no injury as a 

result of the assignment. In its view the foreclosure action "was filed because of his 

default under the terms of the Note and Mortgage; not because of the creation of the 

allegedly 'false 'Assignment. " Although the foreclosure action caused Slorp to incur 

legal fees, the court stated, he incurred those fees because he defaulted, "not because of 

the Assignment. " Thus the district court held that Slorp sustained no injury attributable 

to the allegedly fraudulent assignment. 

This analysis suffers from one key error: It mistakes the source of the injury alleged in 

Slorp 's complaint. Slorp does not attribute his injuries to the false assignment of his 

mortgage; rather, he attributes his injuries to the improper foreclosure litigation. 

According to the complaint, Bank of America (through LSR) filed a foreclosure action 

against Slorp despite its lack of interest in the mortgage; the defendants misled the trial 

court by fraudulently misrepresenting Bank of America's interest in the suit; and Slorp 

incurred damages when he was compelled to defend his interests. If Bank of America had 

no right to file the foreclosure action, it makes no difference whether Slorp previously 

had defaulted on his mortgage. Slorp 's suit to recover damages caused by Bank of 

America's lawsuit satisfies each of the three components of Article III standing. That is 

all that is required for count one, which alleged a violation of the FDCPA-afederal 

statute. See Hollingsworth v. Perry, 133 S. Ct. 2652, 2667 (2013) (stating that "standing 

in federal court is a question of federal law, not state law"); see also Coyne v. Am. 

Tobacco Co., 183 F3d 488, 495 (6th Cir. 1999). Slorp has established standing to seek 

relief under the FDCP A, and the district court erred when it held otherwise. 

One glaring difference is that most of the Beal victims NEVER DEF AUL TED ON THEIR 

MORTGAGES! Beal's MGC fabricated false defaults by intentionally misappropriating Beal 

victims' payments. Beal and his LNV and MGC also acted intentionally in bad faith to prevent 

Defendant's Notice of Related Case Page 15of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 15 of 17
Beal victims from refinancing their mortgages at lower rates, and refuses to report their good 

payment history to credit reporting agencies which also prevents them from refinancing and 

causes their credit score to drop by on average 100 points. Modification offers to Beal victims 

were typically padded with extra fees and predatory rates making the costs so insanely high that 

no one in their right mind would ever agree to them, but that too was by design, so Beal could 

say "we offered them a settlement/modification by they turned it down." 

Is this what any of the Honorable judges reading this, or anyone else, would want done unto 

them? "Do unto others as you would have them do unto you." Jesus of Nazareth - Luke 6:31; 

Matthew 7: 12 

Respectfully Submitted, 

Denise Subramaniam 

Defendant's Notice of Related Case Page 16of16 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 16 of 17
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that a true and correct copy of the foregoing document was 

served upon all counsel of record, pro-se parties and the United States Attorney General and the 

Attorney General of the State of Oregon via the Court's CMIECF system, email, and/or regular 

mail, and/or certified mail with return receipt requested. 

U.S. Department of Justice 

Loretta Lynch, 

U.S. Attorney General 

950 Pennsylvania Avenue, NW 

Washington, DC 20530-0001 

202-514-2000 

Gabrielle D. Richards I Perkins Coie LLP 

1120 NW Couch Street 

10th Floor 

Portland, Oregon 97209-4128 

D. +1.503.727.2255 

F. + 1.503.346.2255 

urichards(a~perkinscoie.com 

Respectfully Submitted, 

Denise Subramaniam 

Case 3:14-cv-01836-MO Document 59 Filed 06/18/15 Page 17 of 17