A Terroristic Divorce

(Filed in Bucks County, PA)

1. Nicole Plank, Esquire, has been attempting to conceal a ‘lack of standing’ in this matter for years, while generating excessive volumes of litigation which has been vexatious, fraudulent and determined to misinform and misdirect this Honorable Court. Her fraudulent efforts persist.

2. Ms. Plank’s deliberate negligence in failing to respond, indicate or demonstrate proper and lawful standing in this matter causes a lack of jurisdiction for the Court. The purported JUDGMENT she again fails to present is defective and void and issued without lawful jurisdiction.

3. There have been no hearings in this matter before the Court of Common Pleas, Bucks County.

4. The timely Reply and Responses by the Defendant to each step of litigation has challenged issues which relate to standing, jurisdiction, and lack of relevant documentation or signed paperwork which indicates the existence of the loan which they are attempting to foreclose.

5. The Plaintiff’s failure and neglect to respond to issues; address questions; avoidance of hearings, testimony and evidence; repeated seeking of improper default judgments; etc… Plaintiffs fraudulent actions demonstrates the motivation and participation in the fraudulent scheme.

Jeffrey Trauger, Esq. of GRIM, BEIHN & THATCHER, filed a foreclosure action without having ANY loan documents on behalf of First Savings Bank of Perkasie.

Protecting Grim Beihn & Thatcher & First Saving Bank of Perkasie by concealing the initial fraud, KTMT would be compensated through the theft of a property valued at $1.2 million for a $1 investment and the costs of litigation – which may include inducements for Court Administration to prevent hearings and obtain default judgments.

AN INAPPROPRIATE RECEIVER

For those reasons set forth above, including but not limited to the fraud and deceptive practices and activities demonstrated and perpetrated by Nicole Plank, Esq;

and

Upon review and consideration of the following Motions filed concurrently and fully incorporated into this document which demonstrate the fraudulent and deceptive actions in this matter currently before the Court;

The Defendant STRONGLY OBJECTS to the appointment of Nicole Plank, Esq. As Receiver.

WHEREAS,

Defendant requests this Honorable Court DISMISS The Plaintiff’s Petition To Appoint Nicole Plank, Esquire, Receiver with prejudice.

UNDO HASTE TO APPOINT RECEIVER

For those reasons set forth above, including but not limited to the fraud and deceptive practices and activities demonstrated and perpetrated by Nicole Plank, Esq;

Where the Plaintiff”S Motion For Disposition Of Plaintiff Petition To Appoint Nicole Plank, Esquire, Receiver has been filed concurrently with a Petition seeking appointment, demonstrates an aggressive and vexatious effort by the Plaintiff seeking haste to prevent a careful review of the matter

and

Upon review and consideration of the following Motions filed concurrently and fully incorporated into this document which demonstrate the fraudulent and deceptive actions in this matter currently before the Court;

The Defendant STRONGLY OBJECTS to the undo haste requested in PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER.

WHEREAS,

Defendant requests this Honorable Court DISMISS PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER with prejudice.

Respectfully,