Free Notice (Other) - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD

Document 435

Filed 11/05/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

INDYMAC BANK, F.S.B. Plaintiff CIVIL ACTION NO. 3:00CV835 (CFD)

V.

MOSTAFA REYAD AND WAFA REYAD Defendants DATE: NOVEMBER 4, 2004

DEFENDANT S JUDICIAL NOTICE

Defendant Mostafa Reyad hereby respectfully submits this Judicial Notice. Plaintiff IndyMac is engaged in vexatious litigation, filing suits against Defendant and his family members, one after the other, alleging the same cause of action. Plaintiff s tactics is unlawful targeting to cripple Defendant pro se s capacity to be in two places in the same time which is logically impossible. In this Court, Defendant must prepare the proposed findings of facts and conclusion of law. In the same time Defendant must prepare the same in the Complex Litigation Court, Waterbury Connecticut.

Plaintiff committed another forgery, and changed the assignee s name on the mortgage assignment executed by Defendant to the benefit of IndyMac, to read

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Bank of New York, Trustee. Defendant never ever has any business whatsoever with Bank of New York, Trustee, or engaged in any business with Bank of New York or any of his subsidiaries. Plaintiff forged the assignment and recorded it in the land records. The assignment is for: 1. IndyMac Loan Number 389345 2. IndyMac Loan Number 389386 Both mortgage loans were executed to the consumer namely, Eugene Chomblo secured by the property 993 Lake Avenue, Greenwich, CT 06831 dated August 31, 1998.

Plaintiff conspired with Bank of New York, Trustee and filed the suit, see Bank of New York, Trustee v. National Funding, et al, X01-CV-00-0171525, Superior Court, J.D. of Waterbury, Connecticut; Revised Complaint attached hereto and see Supplement to Plaintiff s memorandum of law in opposition to Defendant Mostafa Reyad s motion to dissolve the prejudgment remedy and for expedited consideration, dated March 7, 2001 (Doc # 103) attached hereto. Plaintiff claimed damages in eighteen mortgage loans, and the two (2) Chomblo loans are among the eighteen loans claimed on March 7, 2001.

In the Complex Litigation, Honorable Sheedy, J. sue sponte discovered that repetition of claims and Ordered plaintiff; Bank of New York, Trustee to provide

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information relates to IndyMac. See, Judge Sheedy s Order dated 11/2/04, attached hereto.

Moreover, Plaintiff filed in this District, IndyMac Bank, F.S.B. v. David Sherif Reyad and Wafa Reyad, 3:04 CV 798 (CFD), filed on May 7, 2004 and terminated on September 18, 2004. The above defendants were informed by the suit through the electronic system [email protected].

CONCLUSION Notice is hereby given, that, it is impossible that Defendant can be in two courts in the same point of time. Defendant hereby reserves his right to request extension of time as it deems necessary to enable Defendant to defend himself in the two (2) cases filed by the same Plaintiff in two (2) courts, provided that Defendant must file his response to the Complex Litigation on November 16, 2004.

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The Defendant Mostafa Reyad

By: Mostafa Reyad 2077 Center Avenue # 22D Fort Lee, NJ 07024 Home Phone # 201-585-0562 Day Phone # 203-325-4100 Email: [email protected]

CERTIFICATE OF SERVICE

The undersigned certifies that he mailed on the captioned date a true and correct copy to Attorney David Schaefer at 271 Whitney Avenue, New Haven, CT 06511 and hand delivered to Wafa Reyad.

Mostafa Reyad

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