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IN TIIE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COT]NTY OF SNOHOMISH
JACOB D. BRADBURN,

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Plaintiff,
vs.

NO. 11-2-0834s-2 DECLARATION

OF

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RECONTRUST COMPANY, N.4., et. al.

Defendants.

BRADBURN
RESPONSE

IN SUPPORT OF TO MOTION FOR

JACOB

SUMMARY JUDGMENT

1.

My name is Jacob D. Bradburn. I am the Plaintiff in the above captioned proceeding in

the Snohomish County Superior Court.

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am over the age of eighteen and a resident of the

State of V/ashington.

I am competent

to testify with regard to those matters about which I

have personal knowledge gained as will be documented herein.

2.

I have read the Declaration of Abraham K. Lorber which includes 10 pages of 118 from

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my June 71,2013 deposition as Exhibit H. It looks to me like the Defendants cherry-picked

parts of the deposition which they can use to say I took out the loan but didn't pay the loan
and got all the notices I was supposed to.

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3.

As I said in the deposition, my signature was on the Note and Deed. That's not really the

point though, they seem to have a different understanding of the agreement than

had and

DECLARATION OF JACOB BRADBURN IN SUPPORT OF RESPONSE TO MOTION FOR SUMMARY

STAFNE TRUI.'BULL, LLC

239 NORTH OLYMPIC AVENUE ARLINGTON, W498223
TEL. 30.103.8700 /FAX 360.386.'+00s

JUDGMENT-

they think they should take my house even though I did, could and would pay the loan which
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is why we are in court.

4.

Not too long after Mr. Lorber asked me whether I had signed the Note and Deed he

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asked

if I would have any trouble

paying the loan and I told him I would not. Deposition of

Jacob D. Bradburn at 21-22. After

I took out the loan Countrywide sent me booklets

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so I

could make the payments. Id. at 24.

made all of the payments before Bank of America

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bought Countrywide and then the problems started. Id. at24-25;28. Almost as soon as Bank

of America got the loan they started saying I missed payments. Id. at27-28. Bank of America told me to stop making payments on the loan in 2009. Id. at25 30. Bank of America wanted

to refinance or modify my loan but I just wanted to get the problem fixed but Bank of
America wouldn't let me fix the problem even though I had my accounts there. Id. at 26-35; 40-44; 54-55.I even went to the bank in person but no one would tell me how to problem. Id. at32-33.

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fix this

even tried talking to the trustee. Id. at 60. Eventually, they sold the

house without letting me

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fix the

issue.

Id. at 61. They came and changed the locks and threw

away some of my stuff while I was still moving. Id. at36-37;61-71; 83-84.

5.

Bank of America says

I got all of the notices I was supposed to before they

foreclosed.
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See e.g.

Id. at 5l-52. They sent me packages of paperwork all the time, somewhere

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auctions but some were just saying I hadn't made payments or something else. Id. at 49. There

were so many I can't remember every one. Id. at 48-54; 57.It was very confusing; the bank

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kept sending me notices and then cancelling the auction. Id. at 52-53. The one Mr. Lorber
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asked me about

I can't be sure whether I got it

and when.

Id. at 48-52;57. The bank say they

posted

it

at my house on a Friday when

would have been at work but in the picture the

DECLARATION OF JACOB BRADBURN IN SUPPORT OF RESPONSE TO MOTION FOR SUMMARY

STAFNE TRUMBULL, LLC

239 NORTH OLYMPIC AVENUE ARLINGTON, WA 98223
TEL. 30,403,8700 /FAX 360.386.4005

ruDGMENT-2

gara.ge
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door is open and so it doesn't make sense because I never leave the garage door open

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when I'm not home. Id. at 48.

6.

I would have and could have paid what was needed to fix the problem from the time this

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started right up until they sold the house for more than

I owed on it. They never let me do

that. They did not need to do that and selling my house like that was just wrong.1d. passim.

7.
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Finally, I would like to point out that it was never my expectation that the Deed of Trust

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signed would allow anyone to break the

law. It was my expectation

that MERS was the

beneficiary under the contract and that my lender intended the same

thing. If

reasonable

intent of the parties matters, then I believe our intent was to sever the deed of trust from the
note.

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swear under penalty of perjury under the laws of the State of Washington that the foregoing

is true and correct.

DATED this day 21't of October, 2013 inArlington, WA.

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Jacob D. Bradburn

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DECLARATION OF JACOB BRADBURN IN SUPPORT OF RESPONSE TO MOTION FOR SUMMARY

STAFNE TRUMBULL, LLC

239 NORTH OLYMPIC AVENUE ARLINGTON, WA 98223
TEL. 30.,103.8700 /FAX 360.386.4005

ruDGMENT - 3