Denise Subramaniam 

Self-represented 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

fILEri28 .JAN '1615:261JSDC·tJRP 

UNITED ST ATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

LNV CORPORATION 

Plaintiff, 

v. 

DENISE SUBRAMANIAM 

pro per 

Defendant 

Civil Case No. 3:14-cv-01836 

AFFIDAVIT OF DENISE 

SUBRAMANIAM IN SUPPORT 

OF MOTION FOR TEMPORARY 

RULE 65(8) INJUNCTIVE RELIEF 

AFFIDAVIT OF DENISE SUBRAMANIAM 

STATE OF OREGON 

COUNTY OF WASHINGTON 

AFFIDAVIT 

I Denise Subramaniam am over the age of eighteen ( 18) years. I reside in Beaverton Oregon and 

have never been convicted of a crime. I'm fully competent to make this affidavit. The testimony 

contained herein is of my personal knowledge and experience. I swear under the penalty of 

perjury and under the laws of Oregon and the United States that my testimony herein is true and 

accurate. 

On or around 1/2712016 I discovered that the instruments Plaintiff LNV submitted as exhibits to 

its foreclosure complaint and its motion for summary judgment that it claimed to be a ''true and 

accurate copis'' of the "original" note, allonge and assignment of deed of trust cannot possibly be 

genume. 

Dana Lantry endorsed the questioned Note as "Asst. Vice President" of People's Choice Home 

Loan, Inc. On June 28, 2006 an assignment of deed of trust was recorded with Defendant's 

county also endorsed by Dana Lantry which was executed on 12/29/2005 and purports to convey 

beneficial interest in the deed of trust from People's to Homecomings Financial Network, Inc. 

Dana Lantry also purportedly endorsed as "Vice President" of People's Choice Home Loan, Inc., 

allonge that purports to convey beneficial interest to Residential Funding Company LLC. 

Case 3:14-cv-01836-MO Document 121 Filed 01/28/16 Page 1 of 2
These facts on the face of these three instruments submitted into court record by Plaintiff LNV 

support Defendant's claim that LNV manufactured what it submitted to the court as the 

"original'' Note and its allonges after May 2013 and before November 2014 with intent to 

deceive and falsely imply a "cure" of the fatal break in Defendant's chain of title pointed out in 

the Paatalo declaration. 

Affiant and the other Beal victims have named Judge Mosman and three other federal judges and 

four state judges as co-conspirators in a formal criminal complaint filed with the FBI. A copy of 

this complaint has been mailed to James B. Corney, Director of the FBI; and has been, or is 

being, hand delivered to local FBI field offices in more than a dozen states where the Beal 

victims live. Our complaint is for prohibited RICO activities and for conspiracy to deprive us of 

our civil rights under color of law. 

I am disabled, I have been known to be disabled, and the United States recignises me as a 

disabled person. My home provides accommodation for my disabilties pursuant to the ADA and 

Fair Housing Act; the loss of my home would cause me to suffer debilitaing phycial injury; and 

it is nearly impossible for someone with my disabilties to find housing that accommodates my 

special needs. 

An unconstitutional and wrongful sale of my property would cause me to suffer irreparable 

harm. I've motioned the court for temporary stay of a sheriffs sale of my home scheduled for 

tomorrow. There is no time to notify opposing counsel; and may not be in my interests. As a pro 

se, disabled litigant, I've been terribly disadvantaged in this case. I've motioned for 14 days 

temporary injunctive relief; in the hopes I'll be able to find counsel to represent me at a hearing 

for preliminary injunctive relief; and to pursue my Rule 6 motion for relief. 

Further Affiant sayeth not. 

~s __ ___ 

Denise Subramaniam 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

Personally appeared before me, a notary public in and for Washington county Oregon, the above 

on the J. ~day of~teilibet, 1015. 

JcJJ vatr, J,.ol' 

~~ 

-

OFACIALSTAMP 

EMILY ANNE BALILONIS 

NOTARY PUBLIC-OREGON 

COMMISSION NO. 943359 

MY COMMISSION EXPIRES OCTOBER 06. 2019 

Case 3:14-cv-01836-MO Document 121 Filed 01/28/16 Page 2 of 2