Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 1 of 6
`ILLS.
`
`-ssissiSj's.s^ssss'fS.ss:
`
`DISTRICT OF
`
`Mm-phy-Jermaine: Wilson
`In care of: 3282 Meadow Grove Avenue
`Zachary, Louisiana [70791]
`
`{RLED
`
`i 3
`
`I " • I
`g^^^^^^^^^^mWW^^^^?'^^^^^B^^^?»»^^S»^
`
`IN THE FEDERAL MIDDLE DISTRICT COURT OF EAST BATON ROUGE,
`EAST Baton Rouge PARISH
`STATE OF LOUISIANA
`777 FLORIDA STREET, SUITE 139
`BATON ROUGE, LOUISIANA 70801
`
`Murphy-Jermaiae: Wilson
`In Care Of: 3282 Meadow Grove Avenue
`Zachary, Louisiana [70791]
`
`CIVIL ACTION NO.
`
`3:22-cv-00478-SDD-RLB
`
`RESPONSE TO DEFENDANTS
`OPOSITION TO MOTION TO RE-OPEN
`
`Judge
`Shelly D. Dick
`
`PLAINTIFF, (Claimant)
`
`vs.
`
`1.) GINNIE MAE FINANCIAL SERVICES
`now known as GMFS, LLC (GMFS) whose
`CEO is John TerreU Brown Junior acting as
`JOHN TERRELL BROWN JUNIOR,
`PRESIDENT and Agent for GMFS, LLC
`and/or in care of 7389 FLORIDA BLVD.
`SUITE 200A, BATON ROUGE,
`LOUISIANA 70806 (home office address)
`and;
`
`2.) SPECIALIZED LOAN SERVICING,
`LLC (SLS) whose CEO is Tom Millon acting
`as TOM MILLON, CEO and Agent for SLS
`and/or assigns m care of 6200 SOUTH
`QUEBEC STREET, GREENWOOD
`VILLAGE, COLORADO 80111-4720 (home
`office address) and;
`
`3.) Tom Millon acting as TOM MILLON,
`CEO and Agent for SLS, and/or assigns in
`care of; 408 Coco Beach Blvd Apt 502, Rio
`Grande, PR 00745 and;
`
`4.) Ben Thompson acting as BEN
`THOMPSON, SENIOR VP, OPERATIONS
`MANAGER and Agent for GMFS, LLC
`and/or assigns in care of 7389 FLORIDA
`BLVD. SUITE 200A, BATON ROUGE,
`
`
`ILLS.
`
`-ssissiSj's.s^ssss'fS.ss:
`
`DISTRICT OF
`
`Mm-phy-Jermaine: Wilson
`In care of: 3282 Meadow Grove Avenue
`Zachary, Louisiana [70791]
`
`{RLED
`
`i 3
`
`I " • I
`g^^^^^^^^^^mWW^^^^?'^^^^^B^^^?»»^^S»^
`
`IN THE FEDERAL MIDDLE DISTRICT COURT OF EAST BATON ROUGE,
`EAST Baton Rouge PARISH
`STATE OF LOUISIANA
`777 FLORIDA STREET, SUITE 139
`BATON ROUGE, LOUISIANA 70801
`
`Murphy-Jermaiae: Wilson
`In Care Of: 3282 Meadow Grove Avenue
`Zachary, Louisiana [70791]
`
`CIVIL ACTION NO.
`
`3:22-cv-00478-SDD-RLB
`
`RESPONSE TO DEFENDANTS
`OPOSITION TO MOTION TO RE-OPEN
`
`Judge
`Shelly D. Dick
`
`PLAINTIFF, (Claimant)
`
`vs.
`
`1.) GINNIE MAE FINANCIAL SERVICES
`now known as GMFS, LLC (GMFS) whose
`CEO is John TerreU Brown Junior acting as
`JOHN TERRELL BROWN JUNIOR,
`PRESIDENT and Agent for GMFS, LLC
`and/or in care of 7389 FLORIDA BLVD.
`SUITE 200A, BATON ROUGE,
`LOUISIANA 70806 (home office address)
`and;
`
`2.) SPECIALIZED LOAN SERVICING,
`LLC (SLS) whose CEO is Tom Millon acting
`as TOM MILLON, CEO and Agent for SLS
`and/or assigns m care of 6200 SOUTH
`QUEBEC STREET, GREENWOOD
`VILLAGE, COLORADO 80111-4720 (home
`office address) and;
`
`3.) Tom Millon acting as TOM MILLON,
`CEO and Agent for SLS, and/or assigns in
`care of; 408 Coco Beach Blvd Apt 502, Rio
`Grande, PR 00745 and;
`
`4.) Ben Thompson acting as BEN
`THOMPSON, SENIOR VP, OPERATIONS
`MANAGER and Agent for GMFS, LLC
`and/or assigns in care of 7389 FLORIDA
`BLVD. SUITE 200A, BATON ROUGE,
`
`
`
`Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 2 of 6
`
`LOUISIANA 70806 (home office address)
`and;
`
`5.) Will Eglin acting as WILL EGLIN,
`CHIEF FINANCIAL OFFICER and Agent
`for GMFS, LLC and/or assigns in care of
`7389 FLOMDABLVD. SUITE 200A,
`BATON ROUGE, LOUISIANA 70806 (home
`office address), and;
`
`6.) Billy Maxwell acting as BILLY
`MAXWELL, DISTRICT DIRECTOR and
`Agent for GMFS, LLC and/or assigns in care
`of 7389 FLORIDA BOULEVARD, SUITE
`200a, BATON ROUGE, LOUISIANA 70806
`and;
`
`7.) John Terrell Brown Junior actmg as JOHN
`TERRELL BROWN JUNIOR, PRESIDENT
`and Agent for GMFS, LLC and/or assigns in
`care of 7389 FLORTOA BOULEVARD,
`SUITE 200a, BATON ROUGE, LOUISIANA
`70806 and;
`
`8.) Jeffrey Weston acting as JEFFREY
`WESTON, SVP RETAIL OPERATIONS and
`Agent for GMFS, LLC and/or assigns in care
`of 7389 FLORIDA BOULEVARD, SUITE
`200a, BATON ROUGE, LOUISIANA 70806
`and;
`
`9.) Molly Wills acting as MOLLY WILLS,
`SVP and Agent for GMFS, LLC and/or
`assigns in care of 7389 FLORIDA
`BOULEVARD, SUITE 200a, BATON
`ROUGE, LOUISIANA 70806 and;
`
`10.) Tom D'Armond acting as TOM
`D'ARMOND, MANAGER and Agent for
`GMFS, LLC and/or assigns in care of 7389
`FLOMDA BOULEVARD, SUITE 200a,
`BATON ROUGE, LOUISIANA 70806 and;
`
`11.) TRANSUNION CREDIT UNION and
`Christopher A. Cartwright acting as
`CHRISTOPHER A. CARTWRIGHT, CEO
`
`
`
`Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 3 of 6
`
`and Agent for TRANSUNION CREDIT
`UNION and GMFS, LLC and/or assigns, in
`care of 555 WEST ADAMS STREET,
`CHICAGO, ILLINOIS 60661 and;
`
`12.) EQUIFAX CREDIT UNION and Mark
`Begor acting as MARK BEGOR, CEO and
`Agent for EQUIFAX CREDIT UNION and
`GMFS, LLC and/or assigns, in care of
`CORPORATION SERVICE COMPANY, 2
`SUN COURT, SUITE 400, PEACH TREE
`CORNERS, GEORGIA, 30092 and;
`
`13.) EXPERIAN CREDIT UNION and Brian
`Cassin acting as BRIAN CASSIN, CEO and
`Agent for EXPERIAN CREDIT UNION and
`GMFS, LLC and/or assigns, in care of 475
`ANTON BOULEVARD, COSTA MESA,
`CALIFORNIA 92626 and;
`
`14.) COMPUTERSHARE LIMITED who
`merged with SPECIALIZED LOAN
`SERVICING, LLC and Stewart Irving acting
`as STEWART IRVING, CEO and agent for
`COMPUTBRSHARE LIMITED (CL) and/or
`assigns, in care of 6200 SOUTH QUEBEC
`STREET, GREENWOOD VILLAGE,
`COLORADO 80111-4720 (home office
`address), and;
`
`15.) Stewart Irving acting as STEWART
`IRVING, CEO and Agent for
`COMPUTERSHARE LIMITED, and/or
`assigns in care of 6200 SOUTH QUEBEC
`STREET, GREENWOOD VILLAGE,
`COLORADO 80111-4720 (home office
`address) and;
`
`16.) GINNIE MAE FDSTANCIAL SERVICES
`now known as GMFS,LLC, purchased by
`ZAIS FINANCIAL SERVICES, and
`Christian Zugal acting as CHRISTIAN
`ZUGAL CEO and Agent for ZAIS
`FINANCIAL SERVICES and/or assigns in
`care of, 101 Crawfords Corner Road, Suite
`#1206, Hohndel, New Jersey, 07733 (home
`
`
`
`Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 4 of 6
`
`office address) and;
`
`17.) ZAIS FINANCIAL SERVICES then
`MERGED into SUTHERLAND ASSET
`MANAGEMENT, who then changed theu-
`name to READY CAPITAL
`CORPORATION, and Thomas E. Capasse,
`acting as THOMAS E CAPASSE, CEO and
`agent for SUTHERLAND ASSET
`MANAGEMENT AND READY CAPITAL
`CORPORATION and/or assigns in care of
`Avenue oftheAmericas, Floor 7 and 50, New
`York, New York, 10021-1122 (home office
`address) and;
`
`18.) READY CAPITAL CORPORATION is
`managed and advised by WATERFALL
`ASSET MANAGEMENT, LLC (who is a
`Hedge Fund—Pooled investments manager)
`and Thomas E Capasse, acting as THOMAS
`E CAPASSE, PARTNER and agent and/or
`assigns for WATERFALL ASSET
`MANAGEMENT, LLC, and Jack Ross acting
`as JACK ROSS, PARTNER and agent and/or
`assigns for WATERFALL AS SET
`MANAGEMENT, LLC, in care of; Avenue of
`the Americas, Floor 7 and 50, New York, New
`York, 10021-1122 (home of&ce address) and;
`
`19.) FEDERAL HOME LOAN MORTGAGE
`CORPORATION and Michael J DeVito
`acting as MICHAEL J DEVITO, CEO and
`agent aad/or assigns for FEDERAL HOME
`LOAN MORTGAGE CORPORATION, in
`care of; 8200 Jones Branch Drive, McLean,
`Vu-gmia, 22102 and;
`
`20.) Michael J. DeVito acting as MICHAEL J
`DEVITO, CEO and Agent for FEDERAL
`HOME LOAN MORTGAGE
`CORPORATION, and/or assigns in care of
`8200 Jones Branch Drive, McLean, Virginia,
`22102 and;
`
`21.) JOHN DOES 1 THROUGH 100. Jointly
`and Severally, Corporately and Personally.
`
`
`
`Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 5 of 6
`
`DEFENDANTS, (Respondents)
`
`5 RESPONSE TO OPPOSITION BY DEFFENDANTS
`
`COMES now the Claimant/Plamtiff Murphy-Jermaine: Wilson, who is a son of God to
`
`answer the response filed by defendants.
`
`10 1. On January 23, 2023, Plaintiff filed a document titled OBJECTION TO MOTION TO
`
`DISMISS WITH SUPPORTING MEMORANDUM. This title can be found on line 5 of
`
`the document filed by Plaintiff.
`
`2. In the objection filed by plaintiff on January 23, 2023 which is the cutoff day for
`
`objections to the magistrates Report and Recommendation Plaintiff listed all the reasons
`
`15 why Plaintiff objected to the magistrates Report and Recommendation.
`
`3. On February 9, 2023 after receiving notice that an objection was not filed and that the
`
`case would be dismissed Plaintiff filed a hand written document stating plaintiff's intent
`
`to have filed an objection to the magistrates report and recommendation.
`
`4. Defendants were given a negotiable instrument that is well referenced in the documents
`
`20 and evidence dealing with this case that to this day has not been returned to plaintiff and
`
`that instrument is at the heart of this matter before the court.
`
`5. Plaintiff believes and is confident plaintifif he can prove at trial that defendants and
`
`plaintiff have an agreement and contract that all parties have agreed to Plaintiff believes
`
`defendants had enough time to respond to his numerous letters sent by certified mail
`
`25 before this court action was taken therefore Plaintiff is seeking default judgment as the
`
`
`
`Case 3:22-cv-00478-SDD-RLB Document 53 08/23/23 Page 6 of 6
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`agreement between the parties listed on the contract submitted by plaintiff and found in
`
`the evidence of this case is well documented.
`
`Priv
`
`/-Jermaine: Wilson,^3H5rican Freeman
`in of the United States: American National
`Private Citizen of the State of Louisiana
`Special and Private Resident of the Parish of East Baton Rouge
`/All Rights Reserved Without Prejudice
`
`^ 2-^ /^?^ b^-^/^i/^
`^W<^//^ 7o^9/
`
`CERTIFICATE OF SERVICE
`
`I certify that on August 23, 2023,1 caused the ^erggomg to befFte<with the
`Clerk of Court and served upo^'all parties of^cord via email and b^J.S. mail
`'/^/1 -/fffyf^l_
`^/ M^ph/.feifcai&e Wilson
`
`30
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`35
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`40
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`45
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`50
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