' 

Denise Subramaniam 

Self-represented 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

LNV CORPORATION 

Plaintiff, 

v. 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

Civil Case No. 3:14-cv-01836 

DENISE SUBRAMANIAM 

DEFENDANT'S RESPONSE TO 

LNV'S AMENDED COMPLAINT 

pro per 

Defendant 

DEFENDANT'S MOTION FOR JUDICIAL NOTICE OF INFORMATION AND 

CRIMINAL INDICTMENT AND PLEA AGREEMENT OF LORRAINE BROWN 

Comes now Defendant, Denise Subramaniam, representing herself, pursuant to Federal Rule 201 

Judicial Notice of Adjudicative Facts and hereby requests this Court take judicial notice of the 

documents described herein and in support states as follows: 

1. THE DEFENDANT moves this Court to take judicial notice of: 

Information regarding Lorraine Brown, United States of America v. Lorraine Brown, 

Case No. 3:12-cr-198-J-25 MCR, (M.D. Fla.) (attached hereto as "Exhibit A.) 

Plea Agreement of Lorraine Brown, United States of America v. Lorraine Brown, Case 

No. 3:12-cr-198-J-25 MCR, (M.D. Fla.) (attached hereto as "Exhibit B.) 

2. Federal Rule of Evidence 201 -Judicial Notice of Adjudicative Facts: 

(a) Scope. This rule governs judicial notice of an adjudicative fact only, not a 

legislative fact. 

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(b) Kinds of Facts That May Be Judicially Noticed. The court may judicially notice a 

fact that is not subject to reasonable dispute because it: 

(1) is generally known within the trial court's territorial jurisdiction; or 

(2) can be accurately and readily determined from sources whose accuracy 

cannot reasonably be questioned. 

(c) Taking Notice. The court: 

(1) may take judicial notice on its own; or 

(2) must take judicial notice if a party requests it and the court is supplied with 

the necessary information. 

(d) Timing. The court may take judicial notice at any stage of the proceeding. 

(e) Opportunity to Be Heard. On timely request, a party is entitled to be heard on the 

propriety of taking judicial notice and the nature of the fact to be noticed. If the 

court takes judicial notice before notifying a party, the party, on request, is still 

entitled to be heard. 

(f) Instructing the Jury. In a civil case, the court must instruct the jury to accept the 

noticed fact as conclusive. In a criminal case, the court must instruct the jury that 

it may or may not accept the noticed fact as conclusive. 

The Court may take judicial notice of records of any court of record of the United States. 

3. On November 20, 2012, Lorraine Brown, a former executive of Lender Processing 

Services, Inc. (LPS) and DocX LLC, aLPS company, pleaded guilty to conspiracy to 

commit mail and wire fraud. 

4. In mid-2005, Jacksonville, Florida based Fidelity National Financial, Inc. (FNF) 

purchased DocX from Brown and her partners. Through corporate reorganizations within 

FNF, DocX later fell under ownership of Fidelity National Information Services, Inc. 

(FNIS). In mid-2008, FNIS spun off a number of business lines into a new publicly 

traded entity, Lender Processing Services, Inc (LPS) based in Jacksonville, Florida. At 

that time, DocX was re-branded as "LPS Document Solutions, a Division ofLPS." 

Following the spin-off, Brown was the President and Senior Managing Director ofLPS 

Document Solutions. At all times relevant to this Information, Brown was the chief 

executive of the DocX I LPS operations. 

Case 3:14-cv-01836-MO Document 19 Filed 01/28/15 Page 2 of 4
5. THE DEFENDANT moves this Court to take Judicial Notice of Brown's information and 

Plea Agreement because the documents confirm that LPS employees and others engaged 

in a massive fraud scheme in the preparation of hundreds of thousands of mortgagerelated documents, including Mortgage Assignments, and Mortgage Allonges and 

PLAINTIFF contends that the Mortgage Assignments and Mortgage Allonges prepared 

and filed by LPS in her case, bearing the purported signatures of Dana Lantry, Debra 

Lyman, Laura Herrera, Masse Adjetey, Jason J. Vecchio, Betty Wright, Diane M. 

Meistad, Pamela Campbell, Rosyln Hall, B. Burdine, Enedina 0. Sanchez, Mary K. 

Olsen, and Bernadette McDonnell are such fraudulent mortgage assignments. 

6. By way of background, LPS was hired by residential mortgage services to (among other 

things) assist in creating and executing mortgage-related documents filed with recorders' 

offices across the country. 

7. At the direction of Brown and other co-conspirators, employees ofLPS, including those 

who were not authorized to sign documents and temporary workers hired to sign 

documents without quality control and without legally required knowledge specific to the 

Mortgages for which the documents were prepared, began forging and falsifying 

signatures of the mortgage-related documents that they had been hired to prepare and file 

with property recorders' offices. 

8. After these documents were falsely signed and falsely notarized, Brown and her 

coconspirators authorized LPS employees to file and record with property recorders' 

offices across the country. 

9. Many ofLPS's temporary employees signed thousands of mortgage assignments each 

day, often signing the names of other persons on the Mortgage Assignments that would 

Case 3:14-cv-01836-MO Document 19 Filed 01/28/15 Page 3 of 4
then be witnessed and notarized. These employees often signed as officers of banks and 

mortgage companies. The employees signed without reading the documents or in any 

way ascertaining the truth of the matter presented therein, including the grantor, grantee, 

and the date of the purported transfer. 

10. Many ofthe documents, including mortgage assignments and lost note affidavits, were 

later relied upon in court proceedings including foreclosure proceedings and federal 

bankruptcy actions. 

11. Brown admitted that she and others took various steps to conceal their actions from law 

enforcement authorities and others. These steps to conceal included testing new 

employees to ensure they could mimic [forge] signatures. 

12. The documents attached hereto as Exhibits "A" and "B" may be accessed online from 

PACER under United States of America v. Lorraine Brown, Criminal Docket# 3:12-cr00 198-HLA-MCR-1. 

13. Timely written notice of this request is hereby given by email and postal mail service 

upon Defendants' counsel as required by law. 

14. WHEREFORE, pursuant to Federal Rule of Evidence 201 THE PLAINTIFF moves this 

Court to take Judicial Notice of the Information and Plea Agreement of Lorraine Brown 

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

Fla.) without hearing and for such other and further relief as this Court deems just and 

proper under the circumstances. 

Denise Subramaniam, Pro-per 

Case 3:14-cv-01836-MO Document 19 Filed 01/28/15 Page 4 of 4