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1301
FTFM PAPER No. 1301


By Robert M. Janes

RESULTING DOCUMENTS CAN BE TOOLS OF DECEPTION GET PAST
SUPERFICIAL APPEARANCES OF ASSIGNMENTS, DEEDS, TRUSTEE
APPOINTMENTS, ALLONGES, NOTICES OF SALE AND SIMILAR DOCUMENTS
Court decisions often discuss the validity and meaning of a document that is involved with the
ownership and control of a Note or mortgage. The discussion may focus on an assignment,
appointment of a successor trustee, deed, allonge, or paper filed in public records. The
borrower, too often, doesnt know how to challenge or rebut the alleged validity and importance
assigned to those documents by the foreclosure machine. This type of document is frequently
used by the foreclosure machine to gain acceptance of a conclusion that the document doesnt
actually prove. Sure, this is a bit deceptive, but the machine is OK with any win, even one based
on a sleight of hand. There are ways, however, to minimize the likelihood that such a ploy will
confuse you or the judge.
Your opponent will act as if such documents contain all of the information that is needed for the
judge to rule against you. It will act as if the conclusion represented by the document actually
proves itself without requirement of substantiating evidence. That, of course, is not true. These
types of documents are not self-authenticating. Your response, therefore, should help your judge
see that those types of documents contain no intrinsic truths and they only raise questions not yet
answered by your opponent.
When you bought your home, you entered into a purchase contract. You received a deed to your
new home after you paid the purchase money and did the other things required under your
purchase agreement. Similarly, when your lender sold all or part of your mortgage loan, there
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was a sales agreement that led to the assignment of your mortgage loan, or some part of it, to the
buyer. The last documents created in these examples were a deed and an assignment. Those
documents came at the end of the transaction. They were the result of the preceding
agreements that had been made and the instructions given. These are examples of resulting
documents. A resulting document is a paper introduced to prove a point of fact or law but
which, instead, only raises the question of what caused the paper to be created. A resulting
document, by itself, proves only that it was created, but little else.
The resulting document you see may be a notice of sale, an allonge, an appointment of a
substitute trustee, an assignment or possibly a suspicious affidavit. The physical Note is also a
type of resulting document when it bears an endorsement. Papers filed in the public records are
typically resulting documents. Your opponent will try to use them to support its motions and at
trial. The way to challenge a resulting document is the same regardless of the context of its
attempted use by your opponent.
The legal significance of a resulting document cant be understood without first examining the
agreements, related documents and questions raised by its use in your case. Related
documents may include faxes, emails, letters, and other written things that shed light on what
caused the resulting document to come into existence.
A Notice of Default recorded in the public records, for example, is proof that it was created and
recorded. It is not proof, however, that any default exists or that your opponent was ever owed
any obligation from you by law. Whether a resulting document helps prove anything larger than
its mere existence is impossible to know without your opponent proving the circumstances and
documents related to its creation. For each resulting document presented without complete
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backup of everything related to its creation, make note of what your opponent has withheld or
cant prove. Then help your judge understand what is missing and remind your judge that your
opponent, not you, bears the burden of proving the things it has only implied by introducing its
resulting document.
The questions flooding your head when you see a resulting document are important. Sharing
them in a clear and concise way with your judge is good for both of you. A resulting document
demands answers for the who, what, where, when, and why questions the opponent
doesnt want you or your judge to ask. If the opponent had the answers, it would have
introduced the supportive evidence along with the resulting document. Dont let your opponent
off the hook. Highlight the unanswered questions raised by the document to help your judge
understand that your opponent hasnt proven anything of significance by introducing a naked
resulting document. Be constant in asking where the documents, agreements and evidence are
that support the conclusions that are implied or stated by the document. Common sense and the
requirements of the law applicable to your case will guide you evaluating the incomplete story
presented by a resulting document.
A typical residential loan Note is a negotiable instrument. This basically means that there are no
contractual restrictions on its transfer to others, the principal amount owed is a fixed number, and
the Note defines when payments are due. These factors appear to control most determinations as
to whether or not a Note is a negotiable instrument. Interest rates (variable or fixed) and things
that can happen upon delinquency or default rarely carry much weight. Once youve signed the
Note and handed it to the lender, that Note is somewhat like a check you might write against
your personal bank account. The person to whom you give the check can cash it at a bank or can
endorse it over to someone else who may then cash it. Similarly, the lender can endorse the Note
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and hand it over to someone else who may have the right to the payments you make regarding
the Note. Article 3 of the Uniform Commercial Code
1
(UCC) defines rights and obligations
respecting a negotiable instrument.
2
Every state has adopted the UCC.
UCC 3-301 defines who has the right to enforce your Note, that is, who is the Boss of your
Note.
3
Enforce is the key factor. Only the Boss of your Note has the right to demand
payments from you,
4
provide a final accounting of what is owed, if anything,
5
or the right to
foreclose the mortgage-collateral you gave when taking out the loan.
6
The Boss can engage a
servant to do its bidding, but the Boss is the one with the power and the one that has to give the
orders that affect you. Typical of statutory law, the meaning of UCC 3-301 is derived by
analysis and application of other parts of the UCC. The requirements to satisfy Boss status are
extensive. As demonstrated by Chapter 11 and Exhibit D of Fighting The Foreclosure Machine,
the UCC requires us to look at its concepts of negotiation, transfer, delivery,
indorsement,
7
and holder, and whether the transferor intended to deliver the right to enforce
the Note, the requirement that 100% of the Boss rights have to be transferred or else the

1
My references to the Uniform Commercial Code (UCC) are those used by the American Law Institute. A UCC
Locator is available at www.FightingTheForeclosureMachine.com under the Resources tab and you can use it to
locate the UCC in your states laws.
2
See UCC 3-104.
3
If youve read my book, Fighting The Foreclosure Machine, you will recognize the phrase, Boss of the Note, and
understand it to reference the person entitled to enforce the Note per Article 3 of the Uniform Commercial Code. If
you dont know the complexities of how the UCC defines the one person who has the right to enforce the Note, read
Chapter 11 of my book or spend time in a law library.
4
See UCC 3-501(a).
"
Your obligation under the Note may have been satisfied, in full or part, without you knowing it. How much you
have paid does not tell the complete story. Complete information is not available to you outside a court of law. For
example, the Boss of your Note may have exercised endorsement warranty claims against some predecessor who, by
its endorsement, warranted the collectability of your Note. (UCC 3-415). Insurance proceeds collected by the
Boss may have created credits with which you are entitled to offset the amount owed under your Note. The Boss
may have sued or threatened to sue a company that sold your mortgage loan to the Boss, and that may have resulted
in a settlement payment which could also reduce or eliminate what is owed under your Note. The UCC also creates
its own statute of limitations which can bar claims by the Boss if too much time has passed. See pp. 104-107,
Fighting The Foreclosure Machine, for more information about this statute of limitations.
#
$%%& '( )%*+ ,%+(-'-./ 0 1.2'*3( %+ 4+.'56 %2 (6. 7%(. 89 ' :+.+.;*898(. (% .<2%+58<- (6. ,%+(-'-./
7
The rest of the world uses the word endorsement but the UCC likes indorsement. What I have seen is most
judges and attorneys use the e version even when discussing the UCC.
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recipient or transferee has no Boss rights, and all circumstances involving efforts to enforce a
Note that is alleged to have been lost, stolen or destroyed. A piece of paper, for example, that
states Company X assigned the Note to Company Y doesnt explain why that paper was created,
under what arrangements, whether the company signing the document was actually the Boss at
that time (or the Boss agent), the identity of the parties to that arrangement, whether the
transferor refused to promise that it was the Boss with the right to transfer the right to enforce the
Note, whether the transferor intended to deliver 100% of all rights regarding the Note, or
anything else that is relevant to the UCC test. An affidavit stating that the opponent had the
physical Note but that it was lost, stolen or destroyed also falls far short of answering the UCC
essential questions that must be answered before a person who doesnt have physical possession
of the Note can enforce it in accordance with UCC 3-301(iii).
I emphasize the Note, rather than the mortgage, in defensive and offensive strategies. The
content, timing and recording of the mortgage might be important in your state, but, without any
exception of which I am aware, no foreclosure is ever legal if the homeowner owes no obligation
to his or her attacker. The Note is about debt obligations. The most fundamental aspect of a
foreclosure fight is the question of whether a debt is secured by the property targeted for
foreclosure. By all means, use violations of your states foreclosure process or any weakness in
your opponents claim to your mortgage to your advantage. Use whatever law or fact helps you
fend off the foreclosure machine. Dont, however, concede owing any obligation to your
opponent, or to anyone else for that matter, and dont concede that your mortgage is anything
other than collateral pledged solely for use by the Boss of your Note.
The foreclosure machine waves a lot of papers about. It hopes that you and your judge will not
ask too many questions about them. The machine can get away with not having to prove it has
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genuine Boss rights, but only if you let it. Each resulting document presented by your opponent
can be challenged as conclusory and lacking evidentiary significance. Until the what, where,
why, when and who questions have been fully answered by your opponent, the resulting
document is just a piece of paper that doesnt prove anything of legal consequence. Its existence
is proof that it was created and presented by the opponent, but of nothing else. Keep the w
questions active in your mind, demand that your opponent provide answers to those questions,
and help your judge understand how shallow and insignificant the resulting document is without
those questions first being answered with complete and meaningful evidence.
The UCC makes clear that the burden of proof is on the party alleging the right to enforce the
Note. See The UCC and the Burden of Proof, (Chapter 11 in Fighting The Foreclosure
Machine) for more details of how the UCC places the burden of proof on your opponents
shoulders for your protection. If your opponent is the plaintiff, it accepts that burden at the start
of the case. If you are the plaintiff, you shift your burden of proof to your opponent by asking it
to prove its Boss rights in accordance with UCC 3-501(b)(2) and other UCC provisions.
Whether you are the plaintiff or the defendant, your case is more forceful and more educational
for your judge if you request proof of Boss rights before the lawsuit begins by using informal
discovery such as demonstrated by Exhibit E of Fighting The Foreclosure Machine.
Every foreclosure is unique. Describing every circumstance you might encounter is impossible.
Examples should, however, help you learn techniques that can be applied in your own
foreclosure fight with the foreclosure machine. The concept is to use what a resulting document
doesnt prove to deflate the importance assigned to it by your opponent.
Example 1: Your opponent introduces the physical Note with one or more endorsements.
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A. UCC 3-205(a) & (b) establish that only the holder of the Note can make an
effective endorsement on the Note. A person who satisfies holder status in strict
accordance with the UCC is, at that time, Boss of the Note by my terminology. See
Chapter 11 and Exhibit D of Fighting The Foreclosure Machine. Being the holder
of the Note is one way a person can become entitled to enforce the Note (UCC 3-
301(i)). A person can obtain holder status only by satisfying strict UCC
requirements involving negotiation (UCC 3-201), delivery (UCC 1-
201(b)(15)), and transfer (UCC 3-203(a)). A person also has to have physical
possession of the Note to be a holder (UCC 1-201(b)(21)). A signature on the
Note doesnt prove the UCC status of the signer at that time. That script or scribble
doesnt even prove it was placed there by the person whose name appears.
Endorsements, themselves, have no legal meaning. They highlight the need for more
information before any determination can be made regarding the meaning of those
endorsements and the impact of that determination on the paramount question of
whether your opponent now has Boss powers.
B. Where is the opponents evidence that each endorsement was made by the then Boss
of the Note? Even if Company A was the lender, its endorsement a year later on the
Note may be an anomalous endorsement (UCC 3-205(d)) and of no effect if the
lender, as a result of a sale or transfer, wasnt the Boss when endorsing the Note.
C. An undated endorsement raises the question of when the endorsement was added to
the Note, why that endorsement was made, and who was the Boss of the Note at that
time. Dated or not, the same questions as to accuracy and truthfulness are present.
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Each link in the chain of ownership and control of the Note is important in
determining whether the current person claiming Boss rights actually has any.
D. What evidence does the opponent put forward showing that it obtained and evaluated
evidence about the Boss status of the endorser for each endorsement that appears? If
your opponent has no such research, it cant possibly have any basis for alleging that
it obtained the Note from the then Boss of the Note. If your opponent doesnt have
proof of the legal significance of an endorsement, neither you nor your judge can
know, either.
E. What would be necessary to prove that an endorsement is UCC-effective? You arent
looking for an explanation or story from your opponent. Facts are needed. Where are
the agreements, faxes, emails and related documents that preceded and caused the
endorsement to appear on the Note? The details of those papers or the lack of such
papers is what explains the legal significance, if any, of an endorsement. A shortage
of such proof is, in and of itself, good evidence that the endorsement is anomalous
and not an effective endorsement.
F. If the endorsement was placed on the Note by the Boss, that doesnt mean the
transferee became the holder, because, as outlined above, many requirements
precede achievement of Boss status. The underlying agreements or related
documents may show that the then Boss agreed to sign the Note but withheld some
interest in it, thus denying Boss status to the transferee pursuant to UCC 3-203(d).
If that transferee didnt become the Boss, a subsequent transferee of the Note also
would not be a Boss.
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Example 2: The resulting document indicates that it was executed by someone or some company
as agent for someone else.
A. Where are the agreements and related documents that prove that the person who
signed as agent for someone else actually was an agent for that someone else and
acting within the scope of the agency relationship? The existence of an agency
relationship is a fact-intensive issue that requires the presentation of meaningful
evidence before the existence of the alleged agency relationship can be determined.
If your opponent puts on a resulting document that reflects an agents action for an
alleged principal, the opponent is asking you and your judge to believe that the agent
was acting within the scope of a legal agency relationship with the principal. Most
states hold that the party asserting the existence of an agency relationship has the
burden to prove its existence.
8
Check the case law or statutes of your state and youll
likely find similar legal authority. The UCC places the burden of proof on your
opponent. It cant hurt your case if your states law reinforces that burden when your
opponent is relying on the existence of an agency relationship.
B. Where are the agreements and related documents demonstrating that your opponent
determined, as of the time of the alleged agents signature, that the alleged principal
was the Boss of the Note? Even if the signor was agent for a principal, if that

8
See, e.g., Allamon v. Acuity Specialty Products, Civil Action No. 1:10-CV-294-TH (USDCt. E.D. Tex. 6-26-
2012)("Under Texas law, '[a]gency is never to be presumed; it must be shown affirmatively. The party who asserts
the existence of an agency relationship has the burden of proving it.'"); Baroi v. Platinum Condominium
Development, 2:09-CV-00671-PMP-GWF (USDCt. D.Nev. 7-11-2012)(The party asserting an agency relationship
exists bears the burden of proving agency.); Boart Longyear v. Alliance Industries, 12 Civ. 1346 (USDCt. S.D.
N.Y. 6-20-2012)(at fn65 finding that an agency relationship is established when there are facts sufficient to
demonstrate both that the principal intended to grant authority to the agent and the agent assented.); Matter of
Oxford Mgmt, Inc., 4 F.3d 1329 (5th Cir.1993)("Under Louisiana law, an agency relationship cannot be presumed, it
must be clearly established."); and Digital Ally v. Z3 Technology, LLC, 864 F.Supp.2d 1050 (USDCt. D.Kan. 3-29-
2012). Check the case law or statutes of your state and youll likely find legal authority similar to that mentioned in
these cases.
Copyright 2013 Page 10 of 16 FTFM Paper No. 1301
principal was not then the Boss of the Note, the resulting document doesnt prove
Boss rights were transferred to your opponent or to any successor.
C. What if Mortgage Electronic Registration Systems, Inc. (MERS) is mentioned in
your mortgage? The challenges applicable to other alleged agency relationships
apply equally to the use by your opponent of any resulting document that was
allegedly executed by MERS on behalf of some other company. When your
mortgage mentions MERS, you will want to incorporate into your complaint or your
answer to your opponents complaint suggestions like those in Exhibit C of Fighting
the Foreclosure Machine, especially suggested paragraphs ## 29-37. I recommend
these additions to your initial statement in court in order to clarify the presence of the
MERS name in your mortgage loan and to defuse efforts by the foreclosure machine
to argue that you authorized MERS to be agent of the lender or its successors by way
of the mortgage you signed. The machine will make that argument because it
probably has no proof of an actual agency relationship between MERS and the Boss
of your Note at the time the name of MERS is used on a resulting document. As with
alleged agent activities by any person or company, demand proof of an agency
relationship, demand proof that the alleged agent was acting within the scope of the
relationship (if that relationship gets proven), and demand proof that the alleged
principal was the Boss of your Note at that time and authorized by the UCC to direct
that its agent then take some action that related to enforcement of your Note.
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Example 3: The resulting document is a copy of something that was recorded in the public land
records.
A. This resulting document might be a notice of sale, notice of default, substitution of
trustee document, or something else related to the pending or threatened foreclosure.
If the document was actually recorded, it can usually be introduced in court to
demonstrate the fact that it was actually recorded. Other than that, the content of a
recorded document is subject to question. The need for proof about the content of the
document is the same as with any other resulting document. Some states maintain
that a recorded document is presumed to be accurate. Presumed is the operative
word. Raise questions about the conclusions and content of that document, remind
your judge that the burden of proof about the questions rests with your opponent, and
ask the court to not attribute any legal significance to that document beyond the mere
fact of having been created and filed.
B. A notice of default, for example, may have all of the words required by statute or
foreclosure rules. Simply containing those words does not mean that you owe an
obligation to your opponent by law. Your opponent has no right to say a default
exists if you have no obligation under your Note to that company. Only the Boss of
your Note is entitled to enforce your obligations, if any, under your Note. Only the
Boss of your Note is entitled to declare a default.
9
You will most likely enter your
foreclosure lawsuit without having seen UCC-essential proof that your opponent is
the Boss or that your opponent ever obtained any Boss rights from anyone. Your

9
See Default What it means in foreclosure, pg. 52, Fighting The Foreclosure Machine; and UCC 3-501(a)
which clarifies that only the person entitled to enforce the instrument may make presentment, i.e., a demand
related to the Note.
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opponents failure to prove, following your demand for same, that it has the right to
enforce your Note, means that you should deny owing anything to your opponent,
deny that any balance remains due since no Boss of your Note has come forward
saying otherwise, and deny that the meaning of or balance of your Note and mortgage
are none of your opponents business because it is merely an interloper in your
personal affairs. Its failure to provide the requested information is an implicit
admission that you owe it nothing and that it lacks any authority upon which to claim
that you are in default. The statements in a notice of default are inaccurate under
such circumstances and of no legal consequence until and unless your opponent
proves Boss rights in accordance with Article 3 of the UCC.
Example 4: Your opponent introduces an affidavit alleging that it has the physical Note.
A. That affidavit was created to help your opponent. You cant force your opponent to
disclose everything that led to the creation of this document if your opponents
attorney prepared it for use in your lawsuit. Attorney-client privilege usually blocks
that type of inquiry. But there are other ways to object.
B. Ask the obvious question. If your opponent actually had the Note, why didnt it
simply produce the physical Note rather than spend money having an attorney draw
up a paper and having to waste some employees time to say that the opponent has it?
Raise the question so that your judge will also see that the affidavit is suspicious.
C. Where is the physical Note? Your opponent, if claiming to have the Note, is required
to produce it for your inspection when you request to see it. For example, UCC 3-
501(b)(2) states that your opponent must exhibit the instrument. It also has to be
physically available so it can be surrendered when the obligation is extinguished
Copyright 2013 Page 13 of 16 FTFM Paper No. 1301
(UCC 3-501(b)(2)). UCC 3-308(b) also requires the person claiming the right to
enforce the Note to present it, in addition to proving its Boss rights. The UCC
contains no provision that says that a copy or affidavit can suffice when the borrower
demands to see the Note itself. UCC 3-501(b)(3) even affords you the right to
refuse to comply with the demands of your opponent if the Note doesnt have the
required endorsements. That right would be meaningless if you didnt have the right
to inspect the physical Note.
D. If the opponent alleges to have the physical Note, where are the agreements and
related documents, such as emails, faxes and letters, which led to the opponents
possession of the Note? Where is complete proof that your opponent has Boss
powers? By making demands upon you, your opponent has attempted presentment
according to UCC 3-501(a). The right to make demand or presentment for payment
is reserved solely by or on behalf of a person entitled to enforce= (6. 7%(.> '
+.2.+.<5. (% ?@@ ABACD/
E. UCC 3-602(a) affords you no credit of any payment unless it is made to the Boss of
your Note. Yes. Pay the wrong person and your debt doesnt go down. That, too,
shows an intent that you have the right to know the facts, not just self-serving
summaries (like an affidavit) by your opponent; otherwise, you would have no way to
protect yourself from those who claim the rights of the Boss but who cant prove
those rights when challenged.
F. Where are the documents that show that your opponent made an effort to learn
whether the company from which your opponent claims to have obtained rights was
in fact the Boss of the Note? If your opponent did no such research and analysis, it
cant possibly know what Boss rights, if any, were held by that company. Your
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opponents legal rights in the Note are never larger than those of the person from
whom your opponent acquired its alleged interests in your Note.
G. If your opponent was your lender (not a successor who just calls itself lender), does
the affidavit state that it never sold or transferred the Note? If not, why? If the
affidavit doesnt allege that your opponent never transferred or sold the mortgage
loan, the absence of that statement is suspicious, especially because selling and
trading mortgage loans has been such a common lender practice during the past two
decades. Your complaint or answer to a complaint should have contained a statement
that, upon your information and belief, your mortgage loan was, in fact, sold or
transferred by the lender and subsequent persons who claimed some right in your
mortgage loan. The affidavits silence about this subject is also evidence that your
opponent chose to not address your claim that your mortgage loan had been sold or
transferred,
At the commencement of the foreclosure suit, resulting documents will be rushed to the
foreground by your opponent and without any supporting documentation. This will happen as
your opponent tries to defeat your claims using a procedure such as a motion to dismiss, a
demurrer or a motion for summary judgment. Your rebuttal should demonstrate the questions
raised by those documents. Your objective is to highlight questions that arise because of what
the document states and doesnt state. Point out the things that those documents dont address
and cannot prove without information that has not yet been produced by your opponent. Until
you see such information, denying the existence of such supportive evidence is good form. As
discussed in Chapter 12 of Fighting The Foreclosure Machine, there is no need to give your
Copyright 2013 Page 15 of 16 FTFM Paper No. 1301
opponent an easy win in the lawsuit. Study those suggestions, be prepared and force your
opponent into a full disclosure pursuant to your courts rules of discovery.
By the time of trial, permitted discovery will be completed. Chapter 10 and Exhibit F of
Fighting The Foreclosure Machine can help you request and force information from your
opponent during the formal discovery phase. At trial, your opponent will have no more excuses.
Its presentation of any resulting document that is not joined with all of the relevant supportive
documentation will show that your opponent cannot produce genuine evidence that answers all
of the w questions necessitated by its unsupported resulting documents. At this juncture, in
addition to reminding your judge what the resulting documents do not prove, you can also add
that your opponent obviously doesnt have that proof. Request your judge to rule against your
opponent because it, not you, had the burden of proof regarding its alleged right to enforce your
Note. Because it doesnt have the right to enforce your Note, remind your judge that your
opponent also has no right to foreclose on the mortgage that was granted by you solely as
collateral for the person actually entitled to enforce your Note. Do your homework and youll
see that your states law ties the right to foreclose to existence of a defaulted obligation that is
secured by the mortgage.
Your opponent may refuse to comply with your requests for information through your informal
and formal discovery. When I say refuse, I dont care what excuse is used, so long as the
bottom-line is that your opponent doesnt deliver what appear to be the complete records and
documents for every link in your Notes chain of ownership and control. Your opponent may, for
example, persuade a judge that compliance with your requests might violate its private
confidentiality agreement with some company or that your opponents cost to comply with your
request may be too expensive in the opponents view. The particular excuse is not important.
Copyright 2013 Page 16 of 16 FTFM Paper No. 1301
Try to get the complete information, but if your opponent doesnt cooperate, for any reason, then
use the fact of its evidentiary failure to your advantage. Your opponent has the burden of proof.
If it cant or wont produce UCC-essential proof, regardless of the reason, it must accept defeat
for having failed to carry its burden.
The devil is in the details. Avoiding that devil means your opponent needs to keep you and
your judge away from the real and complete facts about its case. Let facts, not assumptions,
guide you. Challenge each resulting document rather than risk your judge mistakenly assuming
that something was proven by the document when, in fact, it was not.
.
Dear Reader:
What you share may help others in their struggles against the foreclosure machine. Please send
your comments to RMJ@FightingTheForeclosureMachine.com.

Thank you.