Wrongful Foreclosure Suit Filed Against Chase Home Finance

by John Watts on April 16, 2012

After a foreclosure in Alabama, normally the mortgage company, such as Chase or Fannie Mae, will sue you to eject or evict you from your home. If the mortgage company has lied to you or otherwise did not have the right to foreclose, you have the option to fight the ejectment suit and file a counterclaim.

You can see an example below of an Alabama homeowner who decided to stay in her home and fight back against the giant mortgage company Chase….

ANSWER AND COUNTERCLAIM

COMES NOW Defendant Lisa Coyne[1] (hereinafter “Defendant”), by and through her attorneys of record and files her Answer to the Mortgage Companies[2] Complaint, and her counterclaim pursuant to Rule 13 of the Alabama Rules of Civil Procedure as follows:

ANSWER

For answer to the Mortgage Companies Complaint, Defendant responds as follows:
1. All material allegations are denied.

AFFIRMATIVE DEFENSES TO THE UNDERLYING

FORECLOSURE AND EJECTMENT ACTION

Defendant alleges that there is no default.
Defendant alleges that the Mortgage Companies did not have actual physical possession of the original note at the time of the foreclosure.
Defendant alleges that acceleration was improper and in violation of the contract between the parties.
Defendant alleges that the Mortgage Companies failed to comply with applicable mortgage servicing regulations, guidelines and agreements and as such a condition precedent to acceleration and foreclosure has been violated requiring dismissal of the underlying foreclosure action.
Defendant alleges that the Mortgage Companies failed to offer pre-foreclosure loss mitigation as required. This failure requires that the underlying action seeking foreclosure be dismissed or abated until such time as this requirement is satisfied.
Defendant alleges that the Mortgage Companies did not have standing to initiate a foreclosure or ejectment action against Defendant.
Defendant alleges that the assignments, endorsements, or allonges to or from Federal National Mortgage Association, Chase Home Finance, LLC or any other entity were void, voidable, illegal, without legal effect and are otherwise invalid and unenforceable as a matter of law.
The foreclosing entity lacked standing to initiate a foreclosure, therefore the foreclosure is void or at least voidable and no title has passed to Plaintiff as there was no legal title to pass to it from the foreclosing entity.
The title taken to the property by the Plaintiff is of no effect and void because the underlying foreclosure was commenced in violation of law on one or more of the following grounds:
1. The foreclosing entity lacked standing to foreclose.
2. The foreclosure was taken in violation of law in that the foreclosing entity did not own the mortgage debt upon which it foreclosed and therefore could pass no legal title to the lands it claimed to foreclose nor could it acquire legal title to the lands that it foreclosed upon.
3. The foreclosure was taken in violation of law in that the default was exaggerated, inflated and based upon improper and illegal mortgage servicing practices on the part of the foreclosing entity and its agents or employees.
4. The Mortgage Companies failed to strictly comply with the requirements set out in Alabama law and the contract between the parties, with respect to notice, time and place and other legal provisions thereby rendering the foreclosure void.
5. The Mortgage Companies failed to engage in loss mitigation required by its agreements and federal servicing guidelines which the entity is subject to, and because of the failure of the condition precedent to foreclosure the acceleration and default were invalid and illegal and renders the foreclosure void.
6. There was no default upon which to accelerate based upon the agreement to modify or forbear the underlying debt.
7. The Mortgage Companies that allegedly foreclosed on Defendant had no authority to do so as they did not own the note and mortgage so as to give them the right to foreclose.
8. The Mortgage Companies committed fraud in that several days before the September 2, 2011 foreclosure date, Mortgage Companies gave Defendant false information about Defendant’s option to reinstate the loan and stop the foreclosure, as described below.

COUNTERCLAIM

Defendant files her counterclaim as follows:

This action arises out of Counterclaim-Defendant Chase’s repeated violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (“FDCPA”), and out of state law violations and out of the invasions of Defendant’s personal and financial privacy by the Mortgage Companies and their agents in their illegal efforts to collect a consumer debt from Defendant.

PARTIES

The Plaintiff Counterclaim-Defendant, Federal National Mortgage Association (“FNMA”) in this action is a foreign corporation doing business in Jefferson County, Alabama.
The Counterclaim-Defendant, Chase Home Finance, LLC (“Chase”) is considered a debt collector under the FDCPA as it was assigned the debt at issue when the debt was allegedly in default in this action and Chase is a foreign corporation of Jefferson County, Alabama, and is added pursuant to Rule 13.
Fictitious Counterclaim-Defendants “A”, “B” and “C” thereby intending to refer to the legal entity, person, firm or corporation which was responsible for or conducted the wrongful acts alleged in the counterclaim; names of the Fictitious parties are unknown to the Defendants at this time but will be added by amendment when ascertained.
Defendant, Lisa Coyne is a resident of Jefferson County, Alabama, and is over the age of 19.

JURISDICTION

Jurisdiction is proper in the Circuit Court of Jefferson, Alabama. The underlying action is based upon a contract executed in Jefferson, Alabama. The action is brought to set aside a foreclosure instituted in Jefferson, Alabama, and is in the nature of a counterclaim to that foreclosure action. The action is brought to enforce the contractual remedies allowed in the mortgage document. The action seeks damages in contract and tort for the actions of the counterclaim defendants with respect to their servicing, representations as to loan modification and the foreclosure on the loan in question.

VENUE

Venue is proper in this Court as Defendant is a citizen of Jefferson County, Alabama and all or substantially all of the wrongs complained of occurred in this county.

STATEMENT OF FACTS

Congress found it necessary to pass the FDCPA due to rampant abusive practices by dishonorable debt collectors. 15 USC § 1692 is entitled “Congressional findings and declaration of purpose” and it states as follows:

(a)        There is abundant evidence of the use of abusive, deceptive, and unfair debt collection practices by many debt collectors. Abusive debt collection practices contribute to the number of personal bankruptcies, to marital instability, to the loss of jobs, and to invasions of individual privacy.
(b)        Existing laws and procedures for redressing these injuries are inadequate to protect consumers.
(c)        Means other than misrepresentation or other abusive debt collection practices are available for the effective collection of debts.
(d)       Abusive debt collection practices are carried on to a substantial extent in interstate commerce and through means and instrumentalities of such commerce. Even where abusive debt collection practices are purely intrastate in character, they nevertheless directly affect interstate commerce.
(e)        It is the purpose of this title to eliminate abusive debt collection practices by debt collectors, to insure that those debt collectors who refrain from using abusive debt collection practices are not competitively disadvantaged, and to promote consistent State action to protect consumers against debt collection abuses.

[Emphasis added].

Defendant incurred a financial obligation that was primarily for personal, family or household purposes (Defendant’s home loan) and is therefore a “debt” as that term is defined by 15 U.S.C. § 1692a(5).
Chase is considered a “debt collector” and began engaging in debt collection activities against Defendant.
Chase failed to make all required disclosures to Defendant in violation of the FDCPA.
Misrepresentations were made by Mortgage Companies regarding the character, amount, or legal status of the debt.
The amount of the debt, the amount of fees and charges, were incorrect and not supported by the law and by the note and mortgage.
The foreclosure was illegal and constituted a threat to take action which Chase was not legally entitled to take.
As set forth below, Mortgage Companies used false representations and/or deceptive means to collect on this debt.
The Mortgage Companies represented to Defendant that if she paid the legally owed amount, the loan would be reinstated and the foreclosure sale on or about September 2, 2011, would be canceled.
Defendant requested, as is her right, an amount to reinstate the loan and stop the foreclosure.
Days later, so that there would be little or no time to comply, Mortgage Companies responded to Defendant’s plea for help when she asked for a reinstatement amount.
On or about August 30, 2011, Mortgage Companies sent a letter by mail to Defendant.
The letter stated that the amount to reinstate the loan was $9,017.80.
In the same letter, however, the reinstatement amount was listed as $9,851.40.
The difference in the two amounts is apparently attributable to estimated and/or anticipated costs and fees.
Given the incredibly short amount of time between the letter mailed on August 30, 2011 and the foreclosure date of September 2, 2011, and the reinstatement deadline of September 1, 2011, the Defendant frantically was able to secure the money for all missed payments but did not have enough money to pay the bogus fees and charges as well as the un-incurred costs and fees.
On or about August 31, 2011, Defendant called Mortgage Companies in a desperate attempt to save her home.
Mortgage Companies told Defendant that they would not accept any amount less than $9,851.40.
Defendant was told that if she paid anything less than the $9,851.40 that the foreclosure sale would still occur on September 2, 2011.
Defendant could have paid the amounts that allegedly were due and owing but could not pay the bogus fees, charges, and expenses that were padded onto the amount allegedly owed.
Heartbroken, Defendant tried to prepare herself and her family for the foreclosure which occurred on September 2, 2011.
Defendant had relied upon the truthfulness of Mortgage Companies in that they would send her a legitimate and honest and accurate reinstatement amount and so Defendant devoted all of her efforts to raising the money instead of seeking other options, including bankruptcy.
This was the intent of the Mortgage Companies – to trick by misrepresentation and suppression, the Defendant into waiting for the reinstatement amount and then making it so inaccurate that Defendant could not pay it and could not exercise other options before the foreclosure.
The collection methods employed by Mortgage Companies were harassing and illegal.
Defendant took out a home loan and such loan was secured by a mortgage on the property owned by Defendant.
Transfers were allegedly made ultimately resulting in Mortgage Companies allegedly having the loan.
Defendant alleges that all such transfers were improper, void, and without legal effect.
On or about September 2, 2011, Mortgage Companies proceeded to foreclose on Defendant’s home.
The sale was without proper notice to Defendant and in direct derogation of Alabama common and statutory law.
Mortgage Companies allege that they are the purchasers of the property made the subject of this suit.
Mortgage Companies have pursued an order ejecting Defendant from her home while representing to the Court that the foreclosure sale was lawful and that the Mortgage Companies had the present right, ownership and authority to pursue the foreclosure and that Mortgage Companies have the right to evict Defendant.
The Mortgage Companies have represented to this Court that they are the proper holder of said mortgage and therefore foreclosed in accordance with Alabama law and their rights under the security agreement.
Defendant alleges that the Mortgage Companies lacked standing to foreclose in that they have no present legal right to enforce the security agreement that underlies the foreclosure action.
Defendant alleges, upon information and belief, that the alleged assignments related to Defendant’s property are defective, void, or otherwise unenforceable.
Defendant contends that said sale was wrongful, illegal, in violation of law and the documents governing the relationship between Defendant and the owners of her mortgage.
Defendant contends that the foreclosing entity lacked standing to initiate a foreclosure and that the foreclosure is void or at least voidable and that no title has passed to Mortgage Companies as there was no legal title to pass to it from the foreclosing entity.
Defendant alleges that the actions of the Mortgage Companies, and its agents, employees and servants were wrongful.
Defendant alleges that the actions of the Mortgage Companies in bringing an action for ejectment from her home and the Mortgage Companies wrongfully foreclosing is a violation of law, wrongful and tortuous and that Mortgage Companies hold no title to the home or property, and that the actions of Mortgage Companies constitute negligence, wantonness, intentional misconduct, fraud, breach of contract, abuse of process and slander of title.
As a direct result of the acts complained of, Defendant has been caused to suffer, and will continue to suffer great mental anguish, damage to her reputation, economic and emotional damages and claim from Mortgage Companies all damages allowable under the law.
All parties acted within the line and scope of any agency relationship and all of their employees and agents acted with the line and scope of their employment and/or agency relationship.
The Mortgage Companies acted as the agents for each other in all of their actions related to the Defendant were taken within the line and scope of their agency relationship with each other.

COUNT ONE

NEGLIGENCE

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies negligently conducted a foreclosure sale on Defendant’s property and have negligently attempted to eject Defendant from the home she rightfully owns.
The Mortgage Companies negligently handled, applied, imposed, created, serviced, and processed payments, charges, fees, expenses, and other aspects of Defendant’s loan and mortgage.
As a direct result of the said negligence, Defendant was injured and damaged as alleged above and has suffered mental anguish, economic injury and all other damages allowed by law.
As a result thereof, the Mortgage Companies are liable for all natural, proximate and consequential damages due to its negligence.

COUNT TWO

WANTONNESS

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies acted with reckless indifference to the consequences, and consciously and intentionally conducted a wrongful foreclosure sale on Defendant’s property and the Mortgage Companies have acted with reckless indifference to the consequences, and consciously and intentionally in instituting this action to eject Defendant from the home she rightfully owns.
The Mortgage Companies wantonly handled, applied, imposed, created, serviced, and processed payments, charges, fees, expenses, and other aspects of Defendant’s loan and mortgage.
These actions were taken with reckless indifference to the consequences, consciously and intentionally in an effort to increase profits for the Mortgage Companies.
The Mortgage Companies knew that these actions were likely to result in injury to Defendant including financial and emotional injuries and mental anguish.
As a result thereof, the Mortgage Companies are liable for all natural, proximate and consequential damages due to its wantonness as well as punitive damages.

COUNT THREE

UNJUST ENRICHMENT

Defendant adopts and realleges all paragraphs as if set out here in full.
The actions of the Mortgage Companies in foreclosing on the home of Defendant in violation of law resulted in the Mortgage Companies being unjustly enriched by the payment of fees, insurance proceeds and equity in the home.
As a result of the Mortgage Companies unjust enrichment, Defendant has been injured and damaged in that Defendant has been forced to pay charges that were illegal, wrong in character, wrong in amount, unauthorized, or otherwise improper under threat of and the actual illegal foreclosure by the Mortgage Companies.
Defendant claims all damages allowable under law as a result of the Mortgage Companies wrongful conduct and unjust enrichment.

COUNT FOUR

WRONGFUL FORECLOSURE

Defendant realleges all prior paragraphs as if set out here in full.
The Mortgage Companies have initiated a foreclosure proceeding against Defendant in violation of law and the Mortgage Companies have wrongfully brought an action for ejectment.
The foreclosure proceeding by the Mortgage Companies and ejectment action by Mortgage Companies were either negligent, wanton or intentional, depending on proof adduced at trial.
As a result thereof, the Mortgage Companies are liable for all natural, proximate and consequential damages due to their actions including an award of punitive damages.

COUNT FIVE

ABUSE OF PROCESS

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies maliciously obtained the issuance of the writ or process of ejectment, from this Court and had it served on Defendant.
The Mortgage Companies abused the said writ or process because the attempt to eject Defendant from her home with the knowledge that she is the rightful owner of her home and that the Mortgage Companies had no right to act against her.
As the proximate result of Mortgage Companies abuse of the said writ or process, Defendant suffered and will continue to suffer injuries and damages.
Defendant claims all damages allowable under law.

COUNT SIX

SLANDER OF TITLE

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies, in filing a foreclosure deed (which is void) have caused a cloud to be placed on the title of the property of Defendant.
As the proximate cause of the Mortgage Companies slandering of Defendant’s title, Defendant was caused to suffer injuries and damages and claims all damages allowable under law.

COUNT SEVEN

BREACH OF CONTRACT

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies breached the contracts with Defendant and thereby caused Defendant incidental and consequential damages (including mental anguish).
Defendant claims all damages allowable under law.

COUNT EIGHT

FRAUD

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies represented to Defendant that if she paid the legally owed amount, the loan would be reinstated and the foreclosure sale on or about September 2, 2011, would be canceled.
Defendant requested, as is her right, an amount to reinstate the loan and stop the foreclosure.
Days later, so that there would be little or no time to comply, Mortgage Companies responded to Defendant’s plea for help when she asked for a reinstatement amount.
On or about August 30, 2011, Mortgage Companies sent a letter by mail to Defendant.
The letter stated that the amount to reinstate the loan was $9,017.80.
In the same letter, however, the reinstatement amount was listed as $9,851.40.
The difference in the two amounts is apparently attributable to estimated and/or anticipated costs and fees.
Given the incredibly short amount of time between the letter mailed on August 30, 2011 and the foreclosure date of September 2, 2011, and the reinstatement deadline of September 1, 2011, the Defendant frantically was able to secure the money for all missed payments but did not have enough money to pay the bogus fees and charges as well as the un-incurred costs and fees.
On or about August 31, 2011, Defendant called Mortgage Companies in a desperate attempt to save her home.
Mortgage Companies told Defendant that they would not accept any amount less than $9,851.40.
Defendant was told that if she paid anything less than the $9,851.40 that the foreclosure sale would still occur on September 2, 2011.
Defendant could have paid the amounts that allegedly were due and owing but could not pay the bogus fees, charges, and expenses that were padded onto the amount allegedly owed.
Heartbroken, Defendant tried to prepare herself and her family for the foreclosure which occurred on September 2, 2011.
Defendant had relied upon the truthfulness of Mortgage Companies in that they would send her a legitimate and honest and accurate reinstatement amount (or that the Mortgage Companies would have accepted the amount actually allegedly owed) and so Defendant devoted all of her efforts to raising the money instead of seeking other options, including bankruptcy.
This was the intent of the Mortgage Companies – to trick by misrepresentation and suppression, the Defendant into waiting for the reinstatement amount and then making it so inaccurate that Defendant could not pay it and could not exercise other options before the foreclosure.
At the time of this representation, Mortgage Companies had no intention of honoring this promise.
The Mortgage Companies suppressed the truth from Defendant as the Mortgage Companies knew that Defendant would have paid the proper reinstatement amount if the Defendant had known the truth.
The Mortgage Companies also knew that if the truth had been told to Defendant about the bogus fees and charges or that Mortgage Companies would have taken less than the false amount represented, then Defendant could have avoided the foreclosure.
The misrepresentations and suppressions concerned material facts relating to the Defendant keeping her home.
The Defendant properly relied upon the false statements and suppressions as no one else in the world would know the mind and intent of the Mortgage Companies except for the Mortgage Companies themselves.
The shock, dismay, fear, anger, embarrassment, humiliation, sense of betrayal, and outrage felt and experienced in the Defendant’s body, mind, and heart, is difficult to describe.
Defendant was stunned to learn that on or about September 19, 2011, Mortgage Companies had filed a lawsuit against Defendant claiming that a valid foreclosure had occurred, demanding that Defendant be thrown out of her home, demanding that the Defendant had loss her right of redemption, and demanding money damages against Defendant.
Defendant lives in her home with her daughter and granddaughter and the realization that Mortgage Companies lied to Defendant and committed the wrongful acts described in this Answer and Counterclaim and now want to force Defendant, her daughter and granddaughter into being homeless has caused great damage to Defendant and her family.
All of the actions of Mortgage Companies were taken in light of a deliberate plan, intent, and scheme to steal the Defendant’s home and to remove any right of redemption and to obtain money damages against Defendant.
All of the misrepresentations and suppressions of material fact which occurred before and after the foreclosure were made intentionally, maliciously, recklessly, negligently, and/or innocently.
The Defendant properly relied upon all such misrepresentations and suppressions of material facts and has been damaged thereby.
At all times the Mortgage Companies have an obligation to speak truthfully and to not lie to Defendant and to not tell half truths to Defendant.
The Mortgage Companies knew at all times the devastating effect that their fraud would have upon the Defendant and this is consistent with the effect that homeowners across Alabama and across this nation are experiencing from the rampant fraud committed by the Mortgage Companies over the last several years.
The Mortgage Companies have refused to apologize to the Defendant for their horrendous conduct.
The Mortgage Companies have refused to set aside the wrongful foreclosure which was accomplished by the Mortgage Companies fraudulent misconduct.
The Mortgage Companies have refused to express, in words or deeds, any remorse or any feelings of guilt or regret for what they have done to the Defendant and what they are continuing to inflict upon the Defendant every day.
Until the Mortgage Companies face reasonable and substantial punitive damage verdicts, they will see no need to change their conduct and attitude which they have towards thousands upon thousands of homeowners across not only Alabama but the nation as well.
Had Defendant been told the truth before September 2, 2011, the Defendant could have taken other steps and actions to prevent the foreclosure and to save her home.
Defendant claims all damages allowable under law.

COUNT NINE

NEGLIGENT AND/OR WANTON HIRING, SUPERVISION, AND/OR TRAINING

Defendant realleges all paragraphs as if set out here in full.
The Mortgage Companies hired, supervised, and/or trained incompetent agents or employees who committed some or all of the wrongful acts set forth in this Answer and Counterclaim.
The Mortgage Companies knew or should have known of the incompetence of these agents or employees.
The Mortgage Companies were negligent or reckless in their hiring, supervision, and/or training which led as a direct and proximate result to the damages suffered by Defendant.
Defendant claims all damages allowable under law.

COUNT TEN

INTENTIONAL AND/OR MALICIOUS CONDUCT

Defendant realleges all paragraphs as if set out here in full.
All actions of the Mortgage Companies were made intentionally and/or malicious and led to the damages of Defendant as a direct proximate result.
Defendant claims all damages allowable under law.

COUNT ELEVEN

VIOLATIONS OF THE FAIR DEBT COLLECTION PRACTICES ACT

15 U.S.C. § 1692 et seq.

Defendant incorporates by reference all of the above paragraphs of this Complaint as though fully stated herein.
The acts and omissions of Chase and its agents constitute numerous and multiple violations of the FDCPA with respect to Defendant.
As a result of the violations of the FDCPA, Defendant is entitled to (1) statutory damages; (2) actual and compensatory damages; and, (3) reasonable attorney’s fees, expenses and costs, from Chase.

COUNT TWELVE

INVASION OF PRIVACY BY INTRUSION UPON SECLUSION

Defendant realleges all paragraphs as if set out here in full.
Alabama law recognizes Defendant’s right to be free from invasions of privacy and Mortgage Companies violated Alabama state law as described in this Complaint.
Congress explicitly recognized a consumer’s inherent right to privacy in collection matters in passing the Fair Debt Collection Practices Act, when it stated as part of its findings:

Abusive debt collection practices contribute to the number of personal bankruptcies, to marital instability, to the loss of jobs, and to invasions of individual privacy.

15 U.S.C. § 1692(a) (emphasis added).

Congress further recognized a consumer’s right to privacy in financial data in passing the Gramm Leech Bliley Act, which regulates the privacy of consumer financial data for a broad range of “financial institutions” including debt collectors (albeit without a private right of action), when it stated as part of its purposes:

It is the policy of the Congress that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers’ nonpublic personal information.

15 U.S.C. § 6801(a) (emphasis added).

Mortgage Companies and/or its agents intentionally, recklessly, and/or negligently interfered, physically or otherwise, with the solitude, seclusion and or private concerns or affairs of the Defendant, namely, by repeatedly and unlawfully attempting to collect a debt and thereby invaded Defendant’s privacy.
Mortgage Companies and its agents intentionally, recklessly, and/or negligently caused emotional harm to Defendant by engaging in highly offensive conduct in the course of collecting this debt, thereby invading and intruding upon Defendant’s right to privacy.
Defendant had a reasonable expectation of privacy in Defendant’s solitude, seclusion, private concerns or affairs, and private financial information.
The conduct of Mortgage Companies and their agents, in engaging in the above-described illegal collection conduct against Defendant, resulted in multiple intrusions and invasions of privacy by the Mortgage Companies which occurred in a way that would be highly offensive to a reasonable person in that position.
As a result of such intrusions and invasions of privacy, Defendant is entitled to actual damages in an amount to be determined at trial from Mortgage Companies.
All acts of Mortgage Companies and their agents and/or employees were committed with malice, intent, wantonness, and/or recklessness and as such Mortgage Companies are subject to punitive damages.

RELIEF REQUESTED

WHEREFORE, Defendant having set forth her claims for relief against the Mortgage Companies, respectfully pray of the Court as follows:

That Defendant recover against the Mortgage Companies a sum to be determined by a jury of her peers in the form of actual damages;
That Defendant recover against the Mortgage Companies a sum to be determined by a jury of her peers in the form of punitive damages;
That Defendant recover against Chase a sum to be determined by a jury of her peers in the form of statutory damages;
That Defendant recover reasonable attorney’s fees, costs, expenses;
That the foreclosure sale be set aside; and
That Defendant have such other and further and proper relief as the Court may deem just and proper.

Respectfully Submitted,
                                                                                    /s/ John G. Watts
John G. Watts (WAT056)
                                                                                    M. Stan Herring (HER037)
                                                                                    Attorneys for Defendant
OF COUNSEL:
Watts & Herring, LLC
The Kress Building
301 19^th Street North
Birmingham, Alabama 35203
(205) 879-2447
(888) 522-7167 facsimile
john@wattsherring.com
stan@wattsherring.com

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