Motion to Dismiss or For More Definite Statement…..

Fresh off of the US BANK v. MATTOS reversal in Hawaii, the Courts are going out of their way to find for the banksters.  I, personally, am not expecting anything different.  The only hope is to get an appeal-able record of the judges’ ignorance.  I hope I’m wrong, and that this judge has his conscience with him when he sits down.  I don’t know.

Let’s hope we get some traction with this motion.  Hearing is July 17.  I’ll keep you posted.

And thanks for staying in tune,  I haven’t had much time, as you can see from the lack of posts.

 

STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY
BRANCH 8
______________________________________________________________________________
HSBC Bank, U.S.A, N.A., as Trustee Case Number: 2017CV000473
for Wells Fargo Home Equity Asset- Case Code: 3040
Backed Securities 2005-2 Trust, Home
Equity Asset-Backed Certificates, Series 2005-2,
c/o 3476 Stateview Boulevard
Fort Mill, South Carolina 29715
Plaintiff, The Amount Claimed Exceeds $10,000
vs.
Roger Rinaldi
22311 121st Street
Bristol, Wisconsin 53104,
Desa Rinaldi
22311 121st Street
Bristol, Wisconsin 53104,
Wells Fargo Bank, N.A.
c/o Officer or Agent
101 N. Phillips Avenue
Sioux Falls, South Dakota 57104,
and
Gray and Associates, LLP
c/o Duncan C. Delhey
16345 W. Glendale Drive
New Berlin, Wisconsin 53151
Defendants.
______________________________________________________________________________
NOTICE OF MOTION AND MOTION TO DISMISS PURSUANT TO
WIS. STAT. SECS. 802.06(2)(a)1., FOR FAILURE TO STATE A CLAIM UPON WHICH
RELIEF MAY BE GRANTED PURSUANT TO WIS. STAT. SEC. 802.06(2)(a)6. AND
ALTERNATIVE MOTION FOR MORE DEFINITE STATEMENT PURSUANT TO WIS.
STAT. SEC. 802.06(5) BY SPECIAL, LIMITED APPEARANCE
(ALL RIGHTS RESERVED)
______________________________________________________________________________
1
PLEASE TAKE NOTICE that the Defendants Roger Rinaldi and Desa Rinaldi (the
Rinaldis), appearing specially and preserving their objections to the capacity of the purported
Plaintiff and the subject matter jurisdiction or competency of the Court, through their attorney
Wendy Alison Nora of ACCESS LEGAL SERVICES, by special, limited appearance, solely and
exclusively for representation of the Rinaldis in proceedings on their Motion to Dismiss
pursuant to Wis. Stat. secs. 802.06(2)(a)1. and 6., and, in the alternative, for More Definite
Statement pursuant to Wis. Stat. sec. 802.06(5), will bring their Motions on for hearing at a time
and place to be set by the Court.
PURSUANT TO WIS. STAT. SEC. 802.06(8)(B), THE RINALDIS EXPRESSLY
RESERVE THEIR RIGHT TO MOVE TO DISMISS THIS ACTION FOR FAILURE TO
JOIN A PARTY INDISPENSABLE UNDER WIS. STAT. SEC. 803.03 AND THEIR
DEFENSE OF RES JUDICATA UNDER WIS. STAT. SEC. 802.06(2)(A)8., WHICH MAY
BE MADE IN ANY PLEADING PERMITTED OR ORDERED UNDER S. 802.01 (1) OR
BY MOTION BEFORE ENTRY OF THE FINAL PRETRIAL CONFERENCE ORDER.
NOW COME the Defendants Roger Rinaldi and Desa Rinaldi (the Rinaldis), appearing
specially and preserving their objections to the capacity of the purported Plaintiff and the subject
matter jurisdiction or competency of the Court, through their attorney Wendy Alison Nora of
ACCESS LEGAL SERVICES, by special, limited appearance solely and exclusively for
representation of the Rinaldis in proceedings on their Motion to Dismiss pursuant to Wis. Stat.
secs. 802.06(2)(a)1. and 6. and for More Definite Statement pursuant to Wis. Stat. sec. 802.06(5)
this action, preserving their subsequent Motion to Dismiss for failure to join a party or parties
indispensable under Wis. Stat. sec. 803.03 and for the Rinaldis’ defense of res judicata under
Wis. Stat. sec. 802.06(2)(a)8. pursuant to Wis. Stat. sec. 802.06(8)(b). In support of their current
Motions, the Rinaldis respectfully show the Court:
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I. Motion to Dismiss the Complaint pursuant to Wis. Stat. sec. 802.06(2)(a)1. for failure to
plead capacity to sue at ¶1 or, alternatively, for More Definite Statement of factual
allegations at ¶1 necessary to establish the identity and capacity of the purported Plaintiff
pursuant to Wis. Stat. sec. 802.06(5)
A. Motion to Dismiss the Complaint pursuant to Wis. Stat. sec. 802.06(2)(a)1. for
failure to plead capacity to sue at ¶1
1. The Complaint alleges at ¶1.
1. HSBC Bank USA, National Association as Trustee for Wells Fargo Home Equity
Asset-Backed Securities 2005-2 Trust, Home Equity Asset- Backed Certificates, Series
2005-2, c/o Wells Fargo Bank, NA., Servicer, is a national banking association, organized
and existing under the laws of the United States of America, authorized to do business in
Wisconsin with one of its principal places of business located at 3476 Stateview
Boulevard, Fort Mill, South Carolina 29715, and is engaged in the business of banking,
lending and related activities (hereinafter “Plaintiff”).
2. The allegations in ¶1 which purport to establish the capacity of “HSBC Bank USA,
National Association as Trustee for Wells Fargo Home Equity Asset-Backed Securities 2005-2
Trust, Home Equity Asset- Backed Certificates, Series 2005-2” (hereinafter HSBC or the
purported Plaintiff) to seek relief in this matter are impossible as a matter of law, are false as a
matter of judicially noticeable fact, and/or are so internally inconsistent and contradictory that
capacity to proceed in this action has not been established.
3. The allegations in ¶1, read grammatically, states that Home Equity Asset- Backed
Certificates, Series 2005-2 is the Plaintiff. As a matter of law, a Certificate Series does not have
a Trustee. The capacity claimed by HSBC as Trustee of a Certificate Series is legally
insufficient. Trusts have Trustees and Certificates of Beneficial Interest (CBIs) are issued by the
Trust. HSBC cannot claim that it is the Trustee of CBIs it issued. It must claim the capacity to
sue as Trustee of a Trust.
4. Although the allegation of the purported Plaintiff’s capacity in ¶1 that HSBC is trustee
3
of that Home Equity Asset- Backed Certificates, Series 2005-2 Certificate Series 2005-2 is
plainly pleaded and should not be disregarded, if the capacity claimed by HSBC as trustee of the
that Home Equity Asset- Backed Certificates, Series 2005-2 is disregarded, then the
identification of HSBC as Trustee would read, “HSBC Bank USA, National Association as
Trustee for Wells Fargo Home Equity Asset-Backed Securities 2005-2 Trust. . . a national
banking association.”
5. Trusts are not national banking associations.
6. National banking associations are not endowed with the power to act as trustees under
12 U.S.C. sec. 24.
7. The authority of a national banking association to act as a trustee is set forth in 12
U.S.C. sec. 92a(a) authorizes and empowers the Office of the Comptroller of Currency (OCC)
“to grant by special permit to national banks applying therefor, when not in contravention of
State or local law, the right to act as trustee, executor, administrator, registrar of stocks and
bonds, guardian of estates, assignee, receiver, or in any other fiduciary capacity in which State
banks, trust companies, or other corporations which come into competition with national banks
are permitted to act under the laws of the State in which the national bank is located.”
8. Pursuant to Wis. Stat. sec. 802.06(2)(a)1., the Rinaldis move to dismiss this action
in the event that the purported Plaintiff purports to be the trustee of a trust. A trust may be a de
jure entity but it is not a national banking association. If HSBC is proceeding as the trustee of a
trust, it must allege its capacity as trustee of a trust and that it has been granted permission to act
in the capacity of a trustee by the OCC, in order to bring an action in its capacity as a trustee in
the courts of the State of Wisconsin.
4
9. Pursuant to Wis. Stat. sec. 802.06(2)(a)1., the Rinaldis move to dismiss this action
in the event that the purported Plaintiff purports to be proceeding in its general corporate
capacity. HSBC cannot proceed in its general corporate capacity and simultaneously claim the
capacity of trustee, whether as trustee of the Wells Fargo Home Equity Asset-Backed Securities
Trust 2005-2 or as trustee of the Wells Fargo Home Equity Asset-Backed Certificate Series,
2005-2.
10. A trust may be a de jure entity but no trust is a national banking association. If
HSBC is proceeding as the trustee of a trust, it must allege its capacity as trustee of a trust and
that it has been granted permission to act in the capacity of a trustee by the OCC under 12 U.S.C.
sec. 92a(a), in order to bring an action in its capacity as a trustee in the courts of the State of
Wisconsin.
11. As a matter of law, the charters of national banking associations at 12 U.S.C. sec. 24
do not provide national banking associations with the power to act as a trustee. Pursuant to Wis.
Stat. sec. 802.06(2)(a)1., the Rinaldis move to dismiss this action, if the identity of the purported
Plaintiff is intended to be construed as meaning that Plaintiff is the Trustee of a Trust because
HSBC has not alleged that it was granted a special permit by the Office of the Comptroller of
Currency to act as a Trustee under 12 U.S.C. sec. 92a(a).
12. Additionally, pursuant to Wis. Stat. sec. 802.06(2)(a)1., the Rinaldis move to
dismiss this action in the event that the purported Plaintiff purports to be the trustee of a
Certificate Series. HSBC cannot be the trustee of the Wells Fargo Home Equity Asset-Backed
Certificate Series 2005-2 as a matter of law.
13. In the alternative, the Rinaldis move for a more definite statement because the
5
allegations in ¶1 are so vague and ambiguous that it is impossible to determine if HSBC claims
to be proceeding in its general corporate capacity as a national banking association, or if HSBC
claims to be as trustee of an identifiable trust, created under statute or at common law, or if
HSBC is claiming to be an indenture trustee, or if HSBC is claiming the right to sue in the name
of the CBIs which may have been issued by the Trustee of a Real Estate Mortgage Investment
Conduit (REMIC) Trust.
14. In the alternative, the Rinaldis move for more definite statement of the allegations in
¶1 of the Complaint stating, with particularity, the capacity of HSBC to seek and obtain relief
from this Court in the following respects:
a. If HSBC is proceeding as the Trustee of the Wells Fargo Home Equity Asset-Backed
Certificates Series, 2005-2, the Wells Fargo Home Equity Asset-Backed Certificates Series,
2005-2 lacks capacity to sue because it is not is not a de jure entity and is not a national banking
association under 12 U.S.C. sec. 24, as incorrectly alleged.
b. If HBSC is proceeding as the Trustee of the Wells Fargo Home Equity Asset-Backed
2005-2 Trust, the Complaint is vague and ambiguous because trusts are not chartered as national
banking associations under 12 U.S.C. sec. 24, as incorrectly alleged.
c. If HSBC is proceedings in its general corporate capacity, the Complaint is vague and
ambiguous because HSBC cannot act as a trustee in its general corporate capacity and must be
granted a special permit from the OCC under 12 U.S.C. sec. 92a(a) to do so, which is not alleged.
15. The allegations in ¶1. of the Complaint are vague and ambiguous because HSBC
appearing to be claiming three possible capacities in a single paragraph. HSBC may be alleging
that it is proceeding in its general corporate capacity as a national banking association or in one
6
of two (2) other possible capacities: as trustee of a trust or as trustee of a Certificates Series it is
not proceeding in its general corporate capacity.
16. The purported Plaintiff also alleges in ¶1, as part of its identity, “c/o Wells Fargo
Bank, N.A., as Servicer.” The designation “Servicer” is a term of art in the financial sector
which applies to an agent servicing the collection of payments on behalf of a principal. An
inference arises from the ambiguous verbiage “c/o Wells Fargo Bank, N.A., as Servicer” that
Wells Fargo Bank, N.A. (Wells Fargo) is the Plaintiff in this action.
17. The purported Plaintiff also provides the address of 3746 Stateview Boulevard in
Fort Mills, South Carolina 29715 as one of the principal business locations of HSBC, in its
general corporate capacity, as trustee of a trust or as trustee of a Certificates Series.
18. Exhibit 1 to the Request for Judicial Notice are the combined results of a search of
the FDIC official website: fdic/bankfind for HSBC Bank USA, National Association at the
following URLs:
URL: HSBC Bank USA, N.A.-FDIC BankFind
https://research.fdic.gov/bankfind/results.html?name=HSBC&fdic=&address=&city=&st
ate=&zip=&bankUrl=
and
URL: HSBC Bank USA, N.A.-FDIC BankFind
https://research.fdic.gov/bankfind/detail.html?bank=57890&name=HSBC Bank USA,
NationalAssociation&searchName=HSBC&searchFdic=&city=&state=&zip=&address=
&searchWithin=&activeFlag=&searchByTradename=false&tabId=2#
19. Request for Judicial Notice Exhibit 1 establishes, as a fact which cannot be
reasonably controverted, that HSBC does not have a business location, principal or otherwise, at
3746 Stateview Boulevard in Fort Mills, South Carolina 29715.

20. Exhibit 2 to the Request for Judicial Notice are the combined results of a search of the
FDIC official website: fdic/bankfind for Wells Fargo Bank, N.A., at the following URLs:
URL: Wells Fargo Search-FDIC BankFind
https://research.fdic.gov/bankfind/results.html?name=Wells+Fargo&fdic=&address=&city=&stat
e=&zip=&bankUrl=
URL: Wells Fargo Bank, N.A.-FDIC BankFind Locations
https://research.fdic.gov/bankfind/detail.html?bank=3511&name=Wells%20Fargo%20Bank,%20
National%20Association&searchName=Wells%20Fargo&searchFdic=&city=&state=&zip=&ad
dress=&searchWithin=&activeFlag=&searchByTradename=false&tabId=2
21. Because the judicially noticeable facts establishing locations for Wells Fargo Bank,
N.A. yielded 6,209 entries, the search was narrowed to the State of South Carolina.
22. The judicially noticeable facts are that, while there are 151 business locations for
Wells Fargo Bank, N.A. in the State of South Carolina, Wells Fargo Bank, N.A. does not have a
business location at 3746 Stateview Boulevard in Fort Mills, South Carolina 29715.
23. A division of Wells Fargo Bank, N.A. does, however, appear to have a business
location in the State of South Carolina, based on Exhibit 3 to the Request for Judicial Notice.
24. The Rinaldis’ Request for Judicial Notice Exhibit 3 establishes, as a fact which
cannot be reasonably controverted, that Wells Fargo Bank, N.A. directed the return of the
November 1, 2011 Assignment of Mortgage (AOM) after it was recorded by the Kenosha County
Register of Deeds to Wells Fargo Bank, N.A. at 3746 Stateview Boulevard in Fort Mills, South
Carolina 29715.
25. Exhibit 3 attached to the Rinaldis’ Request for Judicial Notice, the November 1,
2011 AOM (one of two recorded AOMs on the subject property) identifies Wells Fargo Bank, N.A. as being located at the address claimed by HSBC as one of its principal places of business.
26. The allegations in ¶1 of the Complaint are vague and ambiguous because HSBC does
not have a principal business location at 3746 Stateview Boulevard in Fort Mills, South Carolina
29715 and may be claiming as its principal business address, an address used by Wells Fargo
Bank, N.A. to receive official documents.
B. Motion for More Definite Statement as to ¶1 of the Complaint under Wis. Stat.
sec. 802.06(5)
27. In the alternative, for the reasons set forth above, the Rinaldis cannot reasonably be
expected to frame their responsive pleading to ¶1 because they cannot ascertain the capacity of
HSBC in which HSBC or its “Servicer” Wells Fargo are claiming the capacity to proceed.
28. The purported Plaintiff must be required to plead more definite facts establishing the
identity and capacity of the entity or entities seeking relief in this action not established by the
Complaint at ¶1.
II. Motion to Dismiss First Cause of Action (Reformation of Mortgage) pursuant to Wis.
Stat. sec. 802.06(2)(a)6. for failure to state a claim upon which relief may be granted for
failure to allege “mistake” with particularity and for failure to state a claim for relief as a
matter of law, or alternatively, for More Definite Statement pursuant to Wis. Stat. sec.
802.06(5) as to ¶¶(Second) 8, 9, 10 of the Complaint
A. Failure to plead “mistake” in the First Cause of Action with particularity under
Wis. Stat. sec. 802.03(2)
29. The First Cause of Action pleads for “Reformation of Mortgage” on the basis of an
alleged “mistake” at ¶¶ (Second) 8, 9 and 10.
30. The Rinaldis reserve all of their defenses, including, but not limited to their defenses
under Wis. Stat. secs. 134.15 and 226.14, for subsequent pleadings, if necessary.
31. Wis. Stat. sec. 802.03(2) provides:
9
802.03 Pleading special matters.
(2) Fraud, mistake and condition of mind. In all averments of fraud or mistake, the
circumstances constituting fraud or mistake shall be stated with particularity. Malice,
intent, knowledge, and other condition of mind of a person may be averred generally.
32. There are no factual allegations to support the proposition that a mistake was made in
the creation and execution of the June 10, 2005 Mortgage at ¶¶ (Second) 8, 9 and 10.
33. The allegation in ¶ (Second) 8 that “financing” was provided to Borrower(s) is not
supported by any allegation that Desa “Renaldi” (sic) agreed to be bound to the obligation to pay
the amount of any claimed indebtedness.
34. Desa Rinaldi is not defined as a “Borrower” in ¶3 because she did not make a
promise to pay any debt whatsoever.
35. There is no factual allegation that there was a mistake by any party to the transaction
which resulted in Desa Rinaldi not co-signing a Note.
36. There is no allegation in ¶ 9 that a mistake was made by any party to the transaction
by not naming Desa Rinaldi as grantor of any Mortgage.
37. Furthermore, the document referenced in ¶¶ (Second) 8 and 9 is not identified as a
true and correct copy of what it purports to be.
38. Allegedly “receiving the benefit” of alleged “financing ¶ 9 is not a legal basis for
reforming a security interest to add a party not bound to the underlying obligation.
39. A single conclusory allegation is made at ¶10 that the Mortgage should be reformed
to reflect the “intent of the parties,” contrary to the requirements of Wis. Stat. sec. 802.03, which
requires “mistake” to be stated with particularity.
40. The First Cause of Action in the Complaint must be dismissed for failure to state a
10
claim upon which relief may be granted because facts constituting “mistake” are not set forth
with particularity as required by Wis. Stat. sec. 802.03(2).
B. Failure to state a claim upon which relief may be granted as a matter of law as to
the First Cause of Action
41. On November 16, 2016, all personal liability of the Rinaldis on any claimed prepetition
indebtedness was discharged by Order of the United States Bankruptcy Court for the
Eastern District of Wisconsin (the Bankruptcy Court or WIEB as applicable) in Case No. 16-
27387 in the Chapter 7 Bankruptcy titled In re Rinaldi.
42. Doc. 24 in the Rinaldis’ Chapter 7, WIEB Case No. 16-27387, a true and correct
copy of which is Exhibit 7 to the Rinaldis’ Request for Judicial Notice, which shows that counsel
for “HSBC Bank USA, National Association as Trustee Fo. . .,” Kohner, Mann & Kailas, S.C.
(appearing as counsel herein for the purported Plaintiff), was served at its business location of
record in this action.
43. HSBC Bank USA, N.A. and its agents, Wells Fargo Bank, N.A. as “Servicer” and its
agent and attorneys Kohner, Mann & Kailas, S.C. are in violation of the Discharge Injunction
entered on November 16, 2016 by attempting to reform a Mortgage which is security for the
discharged indebtedness of Roger Rinaldi and which was never owed by Desa Rinaldi.
44. “Equity” cannot reform a Mortgage to retroactively claim a security interest in
indebtedness never owed by Desa Rinaldi, based on a legally unsupportable contingent claim not
made prior to discharge of personal liability for any indebtedness in Chapter 7 proceedings, in
violation of the Discharge Injunction.
45. The First Cause of Action fails to state a claim upon which relief may be granted as a
11
matter of law and must be dismissed under Wis. Stat. sec. 802.06(2)(a)6.
C. Motion for More Definite Statement as to ¶1 of the Complaint under Wis. Stat.
sec. 802.06(5)
46. In the alternative, for the reasons set forth above and hereafter in Section IV. D., E.,
and F. below, the allegations in the First Cause of action are so vague and ambiguous as to the
facts resulting in any “mistake” that the Rinaldis cannot reasonably frame a responsive pleading
to the First Cause of Action.
III. Motion to Dismiss the Complaint the Second Cause of Action (Foreclosure of
Mortgage) pursuant to Wis. Stat. sec. 802.06(2)(a)6. for failure state a claim upon which
relief may be granted as a matter of law
47. The Rinaldis’ Request for Judicial Notice shows, in addition to Exhibit 3, the
November 1, 2011 Assignment of Mortgage (hereinafter AOM #3), Exhibits 4 and 5, which are
two (2) other assignments of the same mortgage granted to Wells Fargo Bank, N.A.
48. The Rinaldis’ Request for Judicial Notice Exhibit 4 is an Assignment of Mortgage
(hereinafter AOM #1) purportedly signed by Herman John Kennerty as “VP of Loan
Documentation” for Wells Fargo Bank, N.A. on March 1, 2010, purportedly notarized on March
10, 2010 by Wendy Albertson Al-Hamadi, and recorded at the Kenosha County Register of
Deeds on April 5, 2010 by the Defendant Gray & Associates, LLP.
49. The Rinaldis’ Request for Judicial Notice Exhibit 5 is an Assignment of Mortgage
(hereinafter AOM #2) purportedly signed and notarized on behalf of Wells Fargo Bank, N.A. on
September 14, 2005, which appeared for the first and only time on November 4, 2011 as Doc. 7-
2 in the Rinaldis’ first-filed bankruptcy case, titled In re Rinaldi, filed on October 14, 2011 as
WIEB Case No. 11-35689.
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50. There are two (2) recorded AOMs and court record of filing of a third unrecorded
AOM, which results in ¶7 being vague and ambiguous because there is no allegation that AOM
#3 is a valid conveyance of a mortgagee interest which was purportedly assigned twice before.
51. Exhibit 6 to the Rinaldis’ Request for Judicial Notice is a true and correct copy the
June 10, 2005 Warranty Deed in the names of Roger Rinaldi and Desa Rinaldi, husband and wife
as survivorship marital property.
52. Exhibit 7 to the Rinaldis’ Request for Judicial Notice is a true and correct copy the
November 16, 2016 Order for Discharge in the Rinaldis’ Chapter 7 WIEB Case No. 16-23787.
53. AOM #3 was recorded when the automatic stay in the Rinaldis’ first-filed bankruptcy
case was in effect and, as a matter of law, is void as being an attempt, contrary to 11 U.S.C. sec.
362 (a)(4) which prohibits “any act to create, perfect, or enforce any lien against property of the
estate” and of 11 U.S.C. sec. 362(a)(5) which prohibits “any act to create, perfect, or enforce
against property of the debtor any lien to the extent that such lien secures a claim that arose
before the commencement of the case under this title.”
54. The issue of law was raised in opposition to a subsequent motion for relief from the
automatic stay in WIEB Case No. 11-35689 but was not finally adjudicated because the
Bankruptcy Court decided that AOM #3 had been equitably assigned to Wells Fargo Asset
Securities Corporation Home Equity Asset-backed Certificates Series 2005-2 Trust (or any
similarly named entity) (the “Trust”) and avoided addressing the violation of the automatic stay.
(Exhibit 8 to the Rinaldis’ Request for Judicial Notice, Doc. 79 in WIEB Case No. 11-35689.)
55. The Complaint alleges at ¶11:
11. Borrower(s) defaulted under the terms and conditions of the Note by failing to pay the
13
monthly payments as they became due.
56. The allegations in ¶11 are vague and ambiguous because ¶11 fails to state to whom
payments under the Note are due and by whom, the amount of the monthly payment, the date the
last monthly payment was received, and what individuals or entities are responsible for making
monthly payments under the “Note,” a true and correct copy of which has not been alleged to
have been attached to the Complaint.
57. Furthermore, no payments by Roger Rinaldi, the apparent sole obligor on the “copy”
(not verified as a true and correct copy) of the attached Note are due, any personal liability
therefor have been merged into the Loan Modification Agreement for which the Rinaldis Request
Judicial Notice of Exhibit 9, for purposes of showing the Court that the purported Plaintiff relies
thereon and not on a Note previously made.
58. Any personal liability of Roger Rinaldi to any party claiming by or through the
purported Plaintiff in any identity or capacity was discharged on November 16, 2016 and Desa
Rinaldi was never obligated to pay the indebtedness which the June 10, 2005 Mortgage was
granted to secure.
59. The signature of Desa Rinaldi on the June 10, 2005 Mortgage was necessary, as a
matter of law, to secure her marital property interest in the Rinaldis’ Hometead.
60. The Complaint alleges at ¶12:
12. The unpaid balance due under the Note and Purchase Money Mortgage is
immediately due and payable.
61. The allegations at ¶12 as to the “Note” are contradicted by the Loan Modification
Agreement attached to the Complaint. No payments are due on the Note which Plaintiff claims
14
was modified on December 17, 2010 (Rinaldis’ Request for Judicial Notice Exhibit 9) and was,
as matter of law, discharged on November 16, 2016 (Rinaldis’Request for Judicial Notice
Exhibit 7).
62. The Complaint alleges at ¶14:
14. As of 05/25/2017, the total indebtedness secured by the mortgaged premises is
computed as follows:
Principal
Accrued Interest
Other Fees
Escrow Advance
Late Charges
Corporate Advance
$198,939.06
27,380.30
90.00
20,331.94
364.00
450.00
TOTAL $247,555.30
*Interest is variable and continues to accrue at the step-rate schedule of 4.000% per year
or $21.80 per diem after 05/25/2017.
Together with all attorneys’ fees, costs, expenses and disbursements incurred before and
after the entry of judgment in this case, and incurred in connection with enforcing the
terms of the Note and Plaintiff’s Purchase Money Mortgage described herein and any
judgment entered in this case.
63. The Complaint alleges at ¶17:
17. Pursuant to Section 846.101 Wis. Stats, and the provisions contained in the Mortgage,
Plaintiff waives a deficiency judgment for any amount borrowers may owe after sale of
the property. Borrowers shall be entitled to possession and any rents, issues, and profits
from the property until confirmation of sale by the Court unless Borrowers abandon the
Premises. Plaintiff agrees to accept sale of the property after the expiration of six (6)
months from entry date of judgment.
64. There is nothing for the purported Plaintiff to “waive” because any claimed
indebtedness has been discharged and the allegation of “waiver” in ¶17 is an attempt to collect
discharged claim of indebtedness.
65. The attempt to collect a debt post-discharge is in violation of the Discharge
15
Injunction (Rinaldis’ Request for Judicial Notice, Exhibit 7.)
66. It is axiomatic that a discharged obligor cannot be liable for interest claimed to be
owed under the discharged instrument, whether the instrument purports to be a negotiable
instrument or a Loan Modification Agreement.
67. A security interest may have survived the November 16, 2016 Discharge, but only if
it attached and was enforceable under Wis. Stat. sec. 409.203 at the time of Order for Discharge
and then only in an action in rem or quasi in rem under Wis. Stat. sec. 801.12 and only by notice
of object of action pursuant to Wis. Stat. sec. 801.12(2).
68. On sufficient allegations and proof, the party entitled to the benefit from the payment
or performance secured by the security interest under Wis. Stat. sec. 409.203(7) may only enforce
the security interest after discharge of personal liability in Chapter 7 proceedings. See Dow
Family, LLC v. PHH Mortgage Corporation, 2014 WI 56, ¶9, 354 Wis. 2d 796, 848 N.W.2d
728, 730 (Wis. 2014) and Wis. Stat. sec. 403.305(1)(a)4.
69. The purported Plaintiff seeks to enforce the security interest by foreclosure on the
Rinaldis’ exempt Homestead. See Wis. Stat. sec. 815.20.
70. In WIEB Case No. 16-27387, the Rinaldis’ exempted their equity in their Homestead
up to the total allowed Homestead exemption for a married couple in the amount of $150,000.00,
notice of which was provided to purported Plaintiff and its “Servicer.” (See Rinaldis’ Request for
Judicial Notice, Exhibits 10 and 11–Exhibit 10: the Rinaldis’ Schedules A/B, C and D and
Exhibit 11: the service matrix in the Rinaldis’ WIEB Chapter 7 Case).
71. No objection was filed to the Homestead exemption claimed by the Rinaldis. (See
Rinaldis’ Request for Judicial Notice, Exhibit 12: Docket Report in WIEB Case No. 16-27387.)
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72. The Complaint in present action contains multiple allegations that a debt is owed to
the ambiguously identified Plaintiff and therefore purports to be in personam and must be
dismissed for failure to state a claim upon which relief may be granted as matter of law against
the Rinaldis personally or their exempt Homestead, absent sufficient allegations that the security
interest attached and was enforceable before November 16, 2016, the date of the Discharge.
IV. Alternative Motion for More Definite Statement under Wis. Stat. sec. 802.06(5) at to
¶¶6, 7, 8, Second 8, 9, 10, 11, 12 and 13, which are so vague and ambiguous that the
Rinaldis cannot reasonably be required to frame a responsive pleading
A. More Definite Statement as to ¶6 of the Complaint
73. The Complaint alleges at ¶6:
6. Borrower(s) executed and delivered a Note and Purchase Money Mortgage for the
consideration expressed therein, copies of which are attached as Exhibits, and the
Purchase Money Mortgage was recorded in the Office of the Register of Deeds for this
County on 06/20/2005 as Document No. 1437622. Plaintiff is the holder of the Note and
Purchase Money Mortgage.
74. The purported Plaintiff does not allege that the attached documents purporting to be
copies of a Note and Purchase Money Mortgage are true copies of what they purport to be; it
does not allege to when, how, to what entity or entities (identifying the entity or entities to which
the documents were delivered and in what format, whether in paper or electronic format), or
where the purported documents were delivered by what entity; it uses the incorrect or ambiguous
designation of “Borrower(s)” contrary to ¶¶2 and 3 which together designate a single individual
as “Borrower,” to wit, Roger Rinaldi; and the identity and capacity of the purported Plaintiff has
been challenged as defectively pleaded above and is not cured by the allegations in ¶6.
75. Furthermore, the facts necessary to establish that the original or copy of the Note
(which is not identified as a true and correct copy) was delivered with the endorsement
17
purportedly affixed thereto bearing the facsimile signature of Joan M. Mills, claiming the
capacity of “Vice President of Wells Fargo Bank, N.A.” and, therefore, a true and correct copy of
the Note purportedly made by Roger Rinaldi and “delivered” to the ambiguously unidentified
entity, is insufficiently pleaded.
76. Under Wisconsin law, a party seeking the remedy of foreclosure, must be the
“holder” of the original Note, to be proved by production of the original or a certified copy
thereof. See Dow Family, LLC v. PHH Mortgage Corporation, 2014 WI 56, ¶7, 354 Wis. 2d
796, 848 N.W.2d 728, 730 (Wis. 2014); PNC Bank, N.A. v. Bierbrauer, 2013 WI App 11,
¶10, 346 Wis.2d 1, 6, 827 N.W.2d 124, 126-127 (Wis. App., 2012).
77. Moreover, the allegations in ¶6 fail to establish that the purported Plaintiff is the
“holder” of a real estate mortgage, “Purchase Money” or otherwise. The purported Plaintiff fails
to allege any facts in support of the conclusion of law that the subject real estate mortgage is a
“document of title” which were delivered as “goods.”
78. “Holder” is defined at Wis. Stat. sec. 401.201(20):
(20) “Holder”, with respect to a negotiable instrument, means the person in possession if
the instrument is payable to bearer or, in the case of an instrument payable to an identified
person, if the identified person is in possession. “Holder”, with respect to a document of
title, means the person in possession if the goods are deliverable to bearer or to the order
of the person in possession.
79. To the extent that the purported Plaintiff is attempting to establish the elements of
Wis. Stat. sec. 409.203, under Dow Family, LLC v. PHH Mortgage Corporation, et al., 2014 WI
56, ¶9, 848 N.W.2d at 731, no allegations appear within the four (4) corners of the Complaint to
establish “attachment and enforceability” of the documents by HSBC under Wis. Stat. sec.
409.203(1) and (2).
18
80. Additionally or in the alternative, the allegations in ¶6 are so vague and ambiguous
that the Rinaldis cannot reasonably be expected to frame a responsive pleading thereto. It is,
therefore, necessary that a more definite statement of the facts upon which the purported Plaintiff
relies to establish its right to enforce the indebtedness represented by the purported documents
attached to the Complaint and referenced in ¶6, particularly:
a. That the documents attached to the Complaint and referenced in ¶6 are true and correct
copies of what they purport to be;
b. When, how, to what entity or entities, or where the purported documents were
delivered by what entity;
c. The identity of the entity or entities to which the documents were delivered and in
what format, whether in paper or electronic format;
d. Alleging whether or not the original Note was negotiated as required by Wis. Stat. sec.
403.201(2) and 403.204;
e. Alleging that Joan M. Mills had the authority to act in the capacity of Vice President
of Wells Fargo Bank, N.A.;
f. Alleging that Joan M. Mills was authorized to place a facsimile signature stamp as an
endorsement on the Note made payable to Wells Fargo Bank, N.A. as required by Wis. Stat. sec.
403.204;
g. Alleging that the original Note was endorsed by authorized facsimile signature of Joan
M. Mills, the date the endorsement was made and the date of delivery of the original Note to
HSBC as Trustee of the Wells Fargo Home Equity Asset-Backed Securities 2005-2 Trust, if the
original Note was transferred as required by Wis. Stat. sec. 403.201(2) and how the transfer was
19
made; and
h. Alleging that the original Mortgage document was delivered to HSBC as Trustee of
the Wells Fargo Home Equity Asset-Backed Securities 2005-2 Trust and how the delivery was
made.
81. The purported Plaintiff is minimally required to attach true and correct copies of
documents upon which it relies to establish its claim, if it intends to rely on them. Failure to do
so, to the extent that the authenticity of the documents is necessary to support the allegations,
renders ¶6 vague and ambiguous.
B. More Definite Statement as to ¶7 of the Complaint
82. The Complaint alleges at ¶7:
7. Wells Fargo Bank, N.A., assigned the Purchase Money Mortgage to Plaintiff by an
assignment dated 10/31/2011 and recorded in the Office of the Register of Deeds for
Kenosha County, Wisconsin on 11/01/2011 as Document No. 1657451. A copy of the
assignment is attached as an Exhibit.
83. The purported Plaintiff does not allege that the copy of the Assignment of Mortgage
(AOM) attached to the Complaint is a true and correct copy of the AOM. The AOM attached to
the Complaint is, on its face, a facsimile copy of a copy of an AOM transmitted to or from “Gray
& End” from an unidentified sender or to an unidentified recipient.
84. The purported Plaintiff does not allege to when, how, to what entity or entities
(identifying the entity or entities to which the AOM was delivered and in what format, whether in
paper or electronic format), or where the AOM was delivered by what entity; and the identity and
capacity of the purported Plaintiff has been challenged as defectively pleaded above.
85. Furthermore, a true and correct copy of the AOM is retrievable in electronic form
20
from the Kenosha County Register of Deeds, the Rinaldis have produced the same as Exhibit 3 to
their Request for Judicial Notice in support of Section I of this Motion, and this Court may rely
on judicially noticeable Exhibit 3 for all purposes in this action, except that it may not
supplement the Complaint by reference to the Rinaldis’ Request for Judicial Notice Exhibit 3
because it is the Plaintiff’s duty to provide true and correct copies of the documents upon which
it relies.
86. The purported Plaintiff is minimally required to attach true and correct copies of
documents upon which it relies to establish its claim, if it intends to rely on them. Failure to do
so, to the extent that the authenticity of the documents is necessary to support the allegations,
results in ¶7 being vague and ambiguous.
87. Additionally, the Rinaldis’ Request for Judicial Notice provides, in addition to
Exhibit 3, the November 1, 2011 Assignment of Mortgage (hereinafter AOM #3), Exhibits 4 and
5, which are two (2) other assignments of the same mortgage.
88. The Rinaldis’ Request for Judicial Notice Exhibit 4 is an Assignment of Mortgage
(hereinafter AOM #1) purportedly signed by Herman John Kennerty as “VP of Loan
Documentation” for Wells Fargo Bank, N.A. on March 1, 2010, purportedly notarized on March
10, 2010 by Wendy Albertson Al-Hamadi, and recorded at the Kenosha County Register of
Deeds on April 5, 2010 by the Defendant Gray & Associates, LLP.
89. The Rinaldis’ Request for Judicial Notice Exhibit 5 is an Assignment of Mortgage
(hereinafter AOM #2) purportedly signed and notarized on behalf of Wells Fargo Bank, N.A. on
September 14, 2005, which appeared for the first and only time on November 4, 2011 as Doc. 7-
2 in the Rinaldis’ first-filed bankruptcy case, titled In re Rinaldi, filed on October 14, 2011 as
21
WIEB Case No. 11-35689.
90. There are two (2) recorded AOMs and court record of filing of a third unrecorded
AOM, which results in ¶7 being vague and ambiguous because there is no allegation that AOM
#3 is a valid conveyance of a mortgagee interest which was purportedly assigned twice before.
91. Moreover, as a matter of law, AOM #3 was recorded when the automatic stay in the
Rinaldis’ first-filed bankruptcy case was in effect and is void as being an attempt, contrary to 11
U.S.C. sec. 362 (a)(4) which prohibits “any act to create, perfect, or enforce any lien against
property of the estate” and of 11 U.S.C. sec. 362(a)(5) which prohibits “any act to create, perfect,
or enforce against property of the debtor any lien to the extent that such lien secures a claim that
arose before the commencement of the case under this title,” which was not adjudicated in
previous WIEB Case No. 11-35689. (See Section III., ¶53, above.)
92. The Rinaldis move for more definite statement of facts to support the apparent claim
that an inadmissible copy of the AOM attached to the Complaint is enforceable against the real
estate owned by Roger Rinaldi and Desa Rinaldi, husband and wife as survivorship marital
property.
C. More Definite Statement as to ¶8 of the Complaint
93. The Complaint alleges at ¶8:
8. The foregoing Note and Purchase Money Mortgage were modified by a Loan
Modification Agreement by and between Plaintiff and Borrower(s), on 01/01/2011,
amending the Purchase Money Mortgage dated 06/10/2005 and recorded in the Office of
the Register of Deeds for this County on 06/20/2005, as Document No. 1437622 which,
among other things, capitalized unpaid interest into the loan, extended the maturity date
to 12/01/2041, provided a step-rate interest rate schedule for an adjustable rate Note and
increased the unpaid principal balance to $201,695.49. A copy of this Agreement is
attached hereto as an Exhibit.
22
94. Once again, purported Plaintiff does not state that the attached document is a true
copy of what it purports to be.
95. There is no allegation that the purported Plaintiff in any capacity or identity
complied with the terms of the Loan Modification Agreement by returning a signed copy of the
Loan Modification Agreement.
96. Moreover, by attaching a copy of the Loan Modification Agreement to the
Complaint for which the Rinaldis’ also Request Judicial Notice as Exhibit 9, the allegations in
the preceding paragraphs are rendered vague and ambiguous. Wells Fargo Bank, N.A. is
identified as the “Lender,” not HSBC in any capacity.
97. The Rinaldis move for more definite statement of facts to explain the effect of the
Loan Modification Agreement attached to the Rinaldis’ Request for Judicial Notice as Exhibit 9,
so that this Court may consider the ambiguity established therein.
D. More Definite Statement as to ¶(Second) 8 of the Complaint
98. The Complaint alleges at ¶(Second) 8:
(Second) 8. Financing was provided to Borrower(s) for the subject property held by them
in title as stated on the Warranty Deed dated 06/10/2015 and recorded with the Kenosha
County Register of Deeds on 06/20/2005, as Document Number 1437621. A copy of the
Warranty Deed is attached hereto as an Exhibit.
99. The allegations in ¶(Second) 8 of the Complaint are vague and ambiguous because
a. There is no definition of the term “financing;”
b. There is no allegation which states what entity provided the “financing;”
c. ¶(Second) 8 of the Complaint fails to state that the Plaintiff financed the transaction at
issue; and
23
d. The term “Borrower(s)” contradicts the allegations in ¶¶2 and 3 or is, at best,
ambiguous as to whom the term applies.
e. The Exhibit referred to in ¶(Second 8) was not attached to the Complaint served upon
the Rinaldis and is, in any event, not alleged to be a true and correct copy of what it purports to
be.
100. The Rinaldis move for more definite statement to clarify the vague and ambiguous
factual allegations in ¶(Second) 8, so that the Rinaldis can reasonably frame a responsive
pleading to ¶(Second) 8.
E. More Definite Statement as to ¶9 of the Complaint
101. The Complaint alleges at ¶9:
9. Borrower(s) received the benefit of the financing from Plaintiff and/or its successors
and assigns to retain the subject property but Defendant, DESA RENALDI, was not
named on the face of the Mortgage dated 06/10/2005 and recorded on 06/20/2005 with
the Kenosha County Register of Deeds, as Document No. 1437622, even though she was
a signatory to the secured instrument. A copy of the recorded mortgage is attached herein.
102. The allegations in ¶9 of the Complaint are vague and ambiguous because
a. Plaintiff’s “successors or assigns” could not have provided “financing” however
defined because the funds for the purported transaction would have to have been provided by the
Plaintiff’s predecessors or their assigns or Plaintiff would not be in the chain of the financing
transactions; and
b. The term “Borrower(s)” is contradictory or, at best, ambiguous as stated at ¶97.d.,
above.
101. The Rinaldis move for more definite statement to clarify the vague and ambiguous
factual allegations in ¶9, so that the Rinaldis can reasonably frame a responsive pleading to ¶9.
24
F. More Definite Statement as to ¶10 of the Complaint
103. The Complaint alleges at ¶10:
10. That as a matter of equity, the Mortgage should be reformed in conformity with the
Warranty Deed and intent of the parties whereby Defendant, DESA RENALDI, is named
on the face of the foregoing Mortgage.
104. The allegations in ¶10 of the Complaint are vague and ambiguous because
a. Desa Rinaldi is not identified as a borrower in ¶3 of the Complaint;
b. Desa Rinaldi did not sign the Note;
c. As a matter of law, Desa Rinaldi was required to signed the Mortgage to encumber her
marital property interest;
d. No debt is owed by Desa Rinaldi to the purported original lender, identified as Wells
Fargo Bank, N.A. (Wells Fargo).
105. The phrase “as a matter of equity” is vague and ambiguous for the reasons stated in
Section II., above.
106. The Rinaldis move for more definite statement to clarify the vague and ambiguous
factual allegations in ¶10, so that the Rinaldis can reasonably frame a responsive pleading to
¶10.
G. More Definite Statement as to ¶11 of the Complaint
107. The Complaint alleges at ¶11:
11. Borrower(s) defaulted under the terms and conditions of the Note by failing to pay the
monthly payments as they became due.
108. The Rinaldis cannot reasonably be expected to frame a responsive pleading to the
allegations in ¶11and move for more definite statement of the facts upon which the purported
25
Plaintiff relies to claim that the either of the Rinaldis owe any amount on an alleged Note and to
what entity the payments are due.
H. More Definite Statement as to ¶12 of the Complaint
109. The Complaint alleges at ¶12:
12. The unpaid balance due under the Note and Purchase Money Mortgage is
immediately due and payable.
110. There is no allegation that Wells Fargo Bank, N.A. is proceeding in its own identity
and capacity and the Mortgage is not alleged in ¶12 to have been assigned to HSBC in any
capacity, but, as set forth above, there are three (3) judicially noticeable AOMs and the one upon
which the purported Plaintiff seeks to rely was recorded in violation of the automatic stay in the
Rinaldis’ earlier bankruptcy proceedings in WIEB Case No. 11-35689.
111. The allegations in ¶12 are vague and ambiguous insofar as insufficient facts are set
forth upon which the Rinaldis can be reasonably expected to frame a response to the allegation
that any amount is owed to the purported Plaintiff under the (discharged) Note and security
interest granted to Wells Fargo Bank, N.A.
112. The Rinaldis move for more definite statement to clarify the vague and ambiguous
factual allegations in ¶12, so that the Rinaldis can reasonably frame a responsive pleading to
¶(12).
I. More Definite Statement as to ¶13 of the Complaint
113. The Complaint alleges at ¶13:
13. Due written notice of default was provided to the Borrower(s) under the terms and
conditions of the Note and Purchase Money Mortgage.
114. Any attempt to give written notice of default on a discharged instrument is a
26
violation of the Discharge Injunction.
115. If written notice of default was given prior to the proceedings in WIEB Case No.
16-27387, purported Plaintiff has failed to state the date upon which any such written notice of
default was sent.
116. If written notice of default was given after the Order for Discharge, any such notice
would be in violation of the Discharge Injunction.
117. The allegation in ¶13 that there has been a default in the terms of the Mortgage
requires allegations that the security interest had attached to the Rinaldis’ Hometead and was
enforceable under Wis. Stat. sec. 409.203 no later than November 15, 2016.
118. The allegations in ¶13 are vague and ambiguous insofar as insufficient facts are set
forth upon which the Rinaldis can be reasonably expected to frame a response to the allegation
that a notice of default was lawfully sent because there is no allegation as to the date such notice
was sent.
J. More Definite Statement as to ¶14 of the Complaint
119. At ¶14 of the Complaint, the purported Plaintiff alleges:
14. As of 05/25/2017, the total indebtedness secured by the mortgaged premises is
computed as
follows:
Principal
Accrued Interest
Other Fees
Escrow Advance
Late Charges
Corporate Advance
$198,939.06
27,380.30
90.00
20,331.94
364.00
450.00
TOTAL $247,555.30
*Interest is variable and continues to accrue at the step-rate schedule of 4.000% per year

or $21.80 per diem after 05/25/2017.
Together with all attorneys’ fees, costs, expenses and disbursements incurred before and
after the entry of judgment in this case, and incurred in connection with enforcing the
terms of the Note and Plaintiff’s Purchase Money Mortgage described herein and any
judgment entered in this case.
120. Because discharged indebtedness does not continue to earn interest, the allegations
in ¶14 are vague and ambiguous insofar as insufficient facts are set forth upon which the Rinaldis
can be reasonably expected to frame a response to the allegation that interest is owed to the
purported Plaintiff.
K. More Definite Statement as to ¶17 of the Complaint
121. The Complaint alleges at ¶17:
17. Pursuant to Section 846.101 Wis. Stats, and the provisions contained in the Mortgage,
Plaintiff waives a deficiency judgment for any amount borrowers may owe after sale of
the property. Borrowers shall be entitled to possession and any rents, issues, and profits
from the property until confirmation of sale by the Court unless Borrowers abandon the
Premises. Plaintiff agrees to accept sale of the property after the expiration of six (6)
months from entry date of judgment.
122. As stated in Sections I., above, the term Plaintiff is ambiguous.
123. As stated in Section II above, there is only one party identified as “Borrower” so the
use of the term “Borrowers” (now appearing without parentheses) in ¶17 is ambiguous.
124. Because discharged indebtedness does not continue to earn interest, the allegations
in ¶14 are vague and ambiguous insofar as insufficient facts are set forth upon which the Rinaldis
can be reasonably expected to frame response to the allegation that interest is owed to the
purported Plaintiff.
125. Because of the ambiguity in ¶17, the Rinaldis not only cannot reasonably be
expected to frame a responsive pleading to the allegations in ¶17, they cannot even ascertain if
28
there is a conflict of interest between them and, therefore, the Rinaldis move for a more definite
statement of what is being waived by the purported Plaintiff.
WHEREFORE, the Rinaldis move:
A. To dismiss the Complaint pursuant to Wis. Stat. sec. 802.06(2)(a)1. for lack of
sufficient identification of the purported Plaintiff’s and lack of sufficient factual allegations to
establish the purported Plaintiff’s capacity to sue under any of its identities claimed in ¶1 or, in
the alternative, for a more definite statement of the purported Plaintiff’s identity and its capacity
to sue.
B. To dismiss the First Cause of Action (Reformation of Mortgage) pursuant to Wis.
Stat. sec. 802.06(2)(a)6. for failure to plead “mistake” with particularity under Wis. Stat. sec.
802.03(2) or, in the alternative, for a more definite statement of the factual allegations which
form the basis of First Cause of Action.
C. To dismiss the Second Cause of Action (Foreclosure of Mortgage) pursuant to Wis.
Stat. sec. 802.06(2)(a)6. as a matter of law for pleading allegations in personam in violation of
the Discharge Injunction in the Rinaldis’ Chapter 7 Bankruptcy Case No. 16-23787.
D. In the alternative, pursuant to Wis. Stat. sec. 802.06(5), for a more definite statement
providing more detailed allegations as set forth above because the Complaint is so vague or
ambiguous that the Rinaldis cannot reasonably be required to frame a responsive pleading to ¶¶
6, 7, 8, (Second 8), 9, 10, 11, 12, 13, 14 and 17 of the Complaint and cannot be reasonably
required to address the relief requested by the purported Plaintiff in this action on the merits
because of the multiple vague and ambiguous allegations in the Complaint.

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