Dr Z

Joseph Zernik, PhD

PO Box 526, La Verne, CA 91750;
Fax: 323.488.9697; Email: jz12345@earthlink.net
Blog: http://inproperinla.blogspot.com/ Scribd: http://www.scribd.com/Human_Rights_Alert

10-05-21 Complaint Filed with FBI, Los Angeles, against Nivie Samaan, Jae Arre Lloyd
(formerly Timothy Lloyd Morrow), Victor Parks, and Maria McLaurin

Steven Goldman, Supervisor

White Collar Crime Squad
FBI Los Angeles, California
Tel: 3130 996 3810
Agent Marie
Tel: 310 996 4133
By Fax: 1-310-996-3359@metrofax.com

The favor of a response within 10 days is requested.

RE: Complaint against Nivie Samaan, Jae Arre Lloyd (formerly Timothy Lloyd Morrow) – a
convicted felon, Victor Parks (Pacific Mortgage Consultants), and Maria McLaurin (formerly
Countrywide Home Loans, Inc, San Rafael – today – Bank of America Home Loans, San Rafael
Branch) – for various types of fraud, including, but not limited to real estate fraud, wire/fax
fraud against an individual and against a financial institution, operating loan/mortgage brokerage
with no license by a convicted felon, and large scale mortgage fraud against the US government.

Dear Supervisor Goldman:

Please accept instant letter and the records linked below as a complaint against Nivie Samaan, Jae Arre Lloyd
(formerly Timothy Lloyd Morrow), Victor Parks, and Maria McLaurin – for various types of fraud, including,
but not limited to real estate and mortgage fraud, wire/fax fraud against an individual and against a financial
institution, operating loan/mortgage brokerage with no license, and large-scale mortgage fraud against the US
government and US taxpayer - in funding sub-prime loans with no authorized underwriting at all.

The pattern of alleged criminalities reflected in instant complaint incurred losses to US taxpayers at billions of
dollars per year at the San Rafael Branch of Countrywide alone – today- the San Rafael Branch Bank of
America Home Loans. It is part of conduct that FBI repeatedly promised US Congress to investigate and later
- to speed-up investigation of.

Following are just highlights of the evidence of the alleged criminal schemes. Voluminous additional
evidence is available upon request:

1) In September 2004 Nivie Samaan provided to Dr Joseph Zernik a Prequalification Letter. [1]
It is alleged that the Prequalification Letter was:
(a) Part of fraudulent inducement,
(b) Forgery, and
(c) Wire/fax fraud.
• Nivie Samaan, a cosmetician, who fraudulently represented herself as a realtor, who “closed
several deals a year” was never qualified for the purchase.

Page 2/7 May 21, 2010

• The fax was never signed by Victor Parks, as opined by highly esteemed fraud expert Robert
Meister. [2]
• The fax was never authored by Victor Parks – Nivie Samaan herself admitted in deposition that
Victor Parks had no direct involvement in the process. [3]
• As documented below, the fax itself was part of a pattern where Nivie Samaan impersonated fax
communication by Victor Parks in September October 2004.
• It is alleged that Nivie Samaan’s husband, Jae Arre Lloyd (formerly Timothy Lloyd Morrow – a
convicted felon) and Victor Parks colluded in this scheme.

2) In September 2004 Nivie Samaan filed a Uniform Residential Loan Applications (1003) with
Countrywide Home Loans, Inc, San Rafael Branch. [4a]
In September 2004 – January 2005, Maria McLaurin and other at Countrywide Home Loans,
Inc, San Rafael Branch, engaged in underwriting and attempted to fund such loan applications.
[4b]
It is alleged that the Loan Applications were:
(a) Part of mortgage fraud against the US government and against Dr Joseph Zernik,
(b) Part of real estate fraud against Dr Joseph Zernik,
(c) Forgery,
(d) Part of a pattern of wire/fax fraud,
(e) Part of operations of an unlicensed loan brokerage by Jae Arre Lloyd,
(f) Part of a pattern of funding of US government backed, uniform residential loan applications
(1003) at Countrywide Home Loan, Inc, San Rafael Branch, with no underwriting by an
authorized underwriter at all – and large scale mortgage fraud against the US government.
• Nivie Samaan, who in her deposition admitted that she was in fact a cosmetician, and that she
never even assisted in any real estate transaction by the time that she filed the fraudulent loan
applications, fraudulently represented herself in such applications as the President of a corporation
with fictitious income and assets.
• The loan applications were never signed by Victor Parks, as opined by highly esteemed fraud
expert Robert Meister. [5]
• The loan applications were prepared by Nivie Samaan and her husband – convicted felon Jae Arre
Lloyd, as admitted by Nivie Samaan I her deposition. [3] Such conduct was in violation of the
law, and also in violation of standard California real estate purchase agreements, which require
that buyer “diligently and honestly” file loan applications.
• The loan applications were transmitted by fax to Countrywide by Nivie Samaan, Borrower, and/or
her husband, Jae Arre Lloyd, as part of fax/wire fraud in 2004, where Nivie Samaan and/or Jae
Arre Lloyd impersonated Victor Parks in wire/fax communications – here – with a financial
institution.
• As explained in Nivie Samaan’s deposition, [3] such conduct was part of the operations in 2004 of
an unlicensed branch of Pacific Mortgage Consultant in Los Angeles, California, by Jae Arre
Lloyd, with no license at all.

3) In or around October 2004 Nivie Samaan, Jae Arre Lloyd, and/or Maria McLaurin engaged in
a wire scheme, where a record titled “Real Estate Purchase Agreement” was forwarded from
Los Angeles, California to San Rafael California.
Later, at an unknown time, such record was retroactively incorporated into Nivie Samaan’s
loan applications file and represented as if it were transmitted by fax on October 25, 2004, 5:03
pm, by Victor Parks, Loan Broker, from Washington State to Countrywide Home Loans, Inc,
in San Rafael, California. [6]
The record and associated conduct are alleged as:

Page 3/7 May 21, 2010

(a) Part of real estate fraud scheme,

(b) Part of a pattern of wire fraud against a financial institution
(c) Part of a mortgage fraud,
(d) Part of a pattern of false retroactive construction of residential loan applications (1003) at
Countrywide Home Loans, Inc, San Rafael Branch, out of compliance of UETA (Uniform
Electronic Transactions Act) and US banking regulations.
• The purchase contract was never faxed by Victor Parks as falsely represented by Nivie Samaan
and by Maria McLaurin. [5]
• As detailed in paper produced by Dr Joseph Zernik, [7] Nivie Samaan’s fax log demonstrated that
this record and others, which were provided by Countrywide as part of a false subpoena
production, [8] with anonymous fax header imprints, all came from Nivie Samaan’s fax machine.
• As documented in Nivie Samaan’s fax log, such transmissions were in fact not to Countrywide
Home Loans, Inc, but to the office of Jae Arre Lloyd, in Los Angeles, California.
• The records produced by Countrywide Home Loans, Inc, failed to provide any authentication of
such banking records, as required by law, and it was impossible to ascertain how and when they
finally arrived at Countrywide Home Loans, Inc. However, circumstantial evidence indicated that
most likely the were forwarded as as PDF attachments to email/wire transmissions by Jae Arre
Lloyd to Maria McLaurin, to circumvent Countrywide Home Loans, Inc, own regulations
regarding transmission of loan applications records.
• It is alleged that in all such instances Nivie Samaan and Maria McLaurin failed to comply with
UETA and US banking regulations, and deliberately produced unauthenticated records, to cover
up the wire/fax fraud scheme.
• It should be noted that in her own subpoena production, [9] Nivie Samaan, buyer and real estate
salesperson for self, failed to produce any copy at all of a real estate purchase agreement, as part of
the real estate fraud scheme.
• In contrast – the subpoena production by Countrywide Home Loans, Inc, provided two copies of a
real estate purchase agreement forwarded to Countrywide by Nivie Samaan and/or Jae Arre
Lloyd, both of which are alleged as part of the real estate fraud, and both of which failed to
comply with UETA and US banking regulations. [8]

4) In 2006-7, Maria McLaurin provided a set of letter and declarations under penalty of perjury,
providing evidence regarding events surrounding the submission and underwriting of Nivie
Samaan’s residential loan applications (1003) in 2004. [13]
Such conduct is alleged as:
(a) Perjury;
(b) Part of the real estate fraud scheme;
(c) Part of deliberate obstruction and perversion of justice;
(d) Part of efforts to conceal the large-scale mortgage fraud against the US government in the
Countrywide San Rafael Branch, which Maria McLaurin managed.

5) Since 2004 and to this date, Jae Arre Lloyd, a convicted felon (on financial crimes) continues to
to hold himself out as a “loan consultant” and operate a loan brokerage branch for Pacific
Mortgage Consultants in Beverly Hills, California, with no license at all. [10]
Such conduct is alleged as:
(a) Violation of various US banking regulations;
(b) Essential to the real estate fraud scheme, which was initiated in 2004, and which continues to
this date.
(c) Essential part of the large-scale fraud in the San Rafael Branch of Countrywide Home Loans,
Inc (today – Bank of America Home Loans) against the US government.

Page 4/7 May 21, 2010

To eliminate a common misunderstanding – Dr Zernik was never involved in any foreclosure, bankruptcy, or
mortgage default of any kind. The fraud schemed described above culminated in November – December
2007: The property at 320 South Peck Drive, Beverly Hills was forcibly and unlawfully taken from Dr
Joseph Zernik by Mr David Pasternak in collusion with Nivie Samaan, Jae Arre Lloyd, Maria McLaurin,
Victor Parks, and others, for private use, and with no compensation to Dr Zernik at all. Consequently, David
Pasternak Conducted conveyance of title of the 320 South Peck Drive property, which was opined by Mr
James Wedick, a decorated FBI veteran, as fraud. [11]

Later, in an August 2008 letter, Mr Wedick recorded his communications with FBI Special Agent assigned to
the case, [12] where the Special Agent agreed with Mr Wedick that Dr Joseph Zernik was a victim of real
estate fraud, and that it was within the duties and obligations of FBI to investigate and provide protection
under such circumstances.

Since January 2008, and to this date, FBI repeatedly promised the US Congress to investigate, and later to
“speed up” investigations related to conduct of sub-prime lenders that caused the current crisis. The case at
hand provided compelling evidence of the large-scale fraud in underwriting of residential loan applications
(1003) at Countrywide Home Loans, Inc., San Rafael Branch, starting as early as 2004. The conduct at the
San Rafael Branch alone is alleged to have resulted in billions of dollars per year in liabilities to the US tax
payer.

It should be noted that Maria McLaurin, who is alleged herein as a key-figure in such large-scale fraud
scheme against the US government in underwriting fraud of sub-prime residential loans, continues to this date
to manage the San Rafael Branch, today - under Bank of America Corporation.

Conditions in Los Angeles County, California, which are reflected in this complaint, are contrary to duties and
obligations of the US government pursuant to international law – the Universal Declaration of Human Rights,
and also contrary to international accords – the Basel Accords on international banking.

Therefore, FBI and the Los Angeles White Collar Crime Squad are requested to initiate investigation
in the matter, to provide Dr Zernik equal protection under the law, and to return to Dr Zernik’s
possession his lawful property at 320 South Peck Drive, Beverly Hills, 90212.

Truly,

Joseph Zernik, PhD

CC:
1) John Dugan – Comptroller of the Currency
john.dugan@occ.treas.gov
2) Office of Comptroller of the Currency
1-713-336-4301@metrofax.com
3) Office of the Honorable Dianne Feinstein, Senator from California
1-415-393-0710@metrofax.com
4) Mr James Wedick, highly decorated FBI veteran and fraud expert.
jwedick@fraudspecialists.com

Page 5/7 May 21, 2010

5) Representative Barney Frank – Chair of the House Banking Committee

1-202-225-6952@metrofax.com
1-202-225-0182@metrofax.com
6) Senator Christopher Dodd – – Chair of the Senate Banking Committee
1-202-224-1083@metrofax.com
7) Senator Carl Levin – Chair of the Senate Investigations Committee
1-202-224-1388@metrofax.com
8) Senator Patrick Leahy – Chair of the Senate Judiciary Committee
1-202-224-3479@metrofax.com
9) Senator John Conyers – Chair of the House Judiciary Committee
1-202-225-0072@metrofax.com
10) UN High Commissioner on Human Rights
11) Basel Accord Committee

LINKS:
[1] Nivie Samaan’s 2004 Prequalification Letter.
• http://inproperinla.com/04-09-07-samaan-s-prequalification-letter.pdf
[2] Opinion on Nivie Samaan’s 2004 Prequalification letter by Fraud Expert Robert Meister
• http://www.scribd.com/doc/29712839/04-09-07-Samaan-v-Zernik-SC087400-Opinion-Letter-of-Robert-
Meister-re-Fraud-in-Nivie-Samaan-s-2004-Prequalificaion-Letter-s
[3] Nivie Samaan’s Deposition
http://www.scribd.com/doc/24991238/07-12-17-Samaan-v-Zernik-SC087400-David-Pasternak-Grant-Deeds-
opined-as-fraud-by-James-Wedick-ss
[4] Nivie Samaan’s residential loan applications
a) Records of the 1003 applications
• http://inproperinla.com/04-09-27-samaan-countrywide-fraudulent-loan-application.pdf
b) Records detailing the alleged fraud in underwriting of the 1003s in the San Rafael Branch of
Countrywide Home Loans, Inc, by Maria McLaurin and others.
• http://www.scribd.com/doc/25695526/04-09-27-Samaan-v-Zernik-SC087400-Nivie-Samaan-apos-s-
Fraudulent-Uniform-Residential-Loan-Applications-1003-and-Their-Fraudulent-Underwriting-by-
Countrywide-Home-Loans-Inc-s
[5] Opinion on Loan Applications by Fraud Expert Robert Meister
• http://www.scribd.com/doc/29714059/04-09-27-Opinion-Letter-by-Fraud-Expert-Robert-Meister-re-
Countrywide-apos-s-Uniform-Residential-Loan-Applications-1003-by-Nivie-Samaan-s
[6] Record of real estate purchase contract, which was forwarded to Countrywide Home Loans, Inc around
October 2004, is provide as pages
• http://www.scribd.com/doc/31676831/07-02-08-Samaan-v-Zernik-SC087400-Countrywide-Subpoena-
Production-Alleged-as-Fraud-s
[7] Record filed by Dr Joseph Zernik providing evidence of various alleged criminalities in the record
represented as a real estate purchase contract, which was produced by Countrywide Home Loans, Inc, and
filed as evidence by Nivie Samaan in court, Such evidence included, but was not limited to a copy of Nivie
Samaan’s fax log and other evidence of fax/wire and other fraud by Nivie Samaan and others.
• http://www.scribd.com/doc/30974313/08-04-17-Zernik-v-Connor-et-al-2-08-cv-01550-Dkt-045-
Countrywide-s-Fraudulent-Real-Estate-Purchase-Agreement-Record-s
[8] Subpoena production by Countrywide Home Loans, Inc, including various records that evidence wire/fax
fraud and other alleged criminalities by Nivie Samaan and/or Jae Arre Lloyd and/or Maria McLaurin.
Countrywide provided five (5) times between August 2006 and April 2007 similar records productions in
response to legal subpoenas. Each included hundreds of false and deliberately misleading banking records,

Page 6/7 May 21, 2010

alleged as fraud. Furthermore, each was also alleged as fraud in its entirety - attempting to recreate residential
loan application files after the fact, and also attempting to retroactively fabricate loan underwriting histories.
It is claimed that the Countrywide subpoenas are the best evidence regarding the true nature of the current
"Sub Prime Crisis". It was provided to FBI already in January 2007, with a complaint of large scale fraud by
Countrywide against the US taxpayer. To this date - FBI is refusing to investigate.
The subpoena included two different copies of a real estate purchase agreement, both alleged as fraud. Neither
of them was authenticated as required of such banking records pursuant to UETA (Universal Electronic
Transactions Act) and US banking regulations, and neither was valid as court evidence. Both records were
alleged as fraud through collusion by Nivie Samaan, Jae Arre Lloyd (her husband and a convicted felon under
a previous identity - Timothy Lloyd Morrow), Victor Parks (Pacific Mortgage Consultants Loan Broker), and
Maria McLaurin (Countrywide Home Loans, San Rafael Branch Manager):
a) Pages 26-39 - fax record, missing its cover sheet, bearing fax header imprint by Spellbound (Samaan's
purported business), and date and time stamp of October 22, 2004, 11:20am. The origin of this copy
is unknown, but it was apparently rejected by Countrywide (see cover page of copy #2), since it was
missing Samaan's initials on the acknowledgment on the final page (indicated by an arrow).
b) Pages 272-286 - fax record, bearing a fraudulent fax cover sheet, falsely claiming that it was faxed by
Victor Parks, Loan Broker, on October 25, 2004, 5:03 pm. In fact, throughout the transactions,
Samaan was impersonating Victor Parks in fax transmissions, as best documented in email notices by
Michael Libow, dated October 19-20, 2004. A full record, filed under Zernik v Connor et al, detailed
the multiple levels of fraud embedded in this record.
The San Rafael Branch was a wholesale branch, and all records were required to be provided by the Loan
Broker, not the Borrower, and certified by the Loan Broker. As admitted by Nivie Samaan in her July 10,
2006 deposition (see separate record, posted here), Victor Parks had nothing to do with the loan applications.
Nivie Samaan and her husband, Jae Arre Lloyd fraudulently conducted the transactions instead.
• http://www.scribd.com/doc/31676831/07-02-08-Samaan-v-Zernik-SC087400-Countrywide-Subpoena-
Production-Alleged-as-Fraud-s
[9] Nivie Samaan’s Subpoena Production
• http://www.scribd.com/06-07-10-Samaan-v-Zernik-SC087400-Nivie-Samaan-s-Subpoena-Production-
Alleged-As-Fraud/d/31676107
[10] Web records regarding conduct by Jae Arre Lloyd to this date, which is alleged as prohibited by law:
a) Advertisement by Jae Arre Lloyd (formerly Timothy Lloyd Morrow) a convicted felon on financial
crimes, holding himself out as a mortgage consultant, operating a loan brokerage in Beverly Hills
California to this date, with no license at all.
• http://www.scribd.com/09-09-28-Pacific-Mortgage-Consultants-Jae-Arre-Lloyd-formerly-Timothy-
Lloyd-Morrow-a-convicted-felon-Business-Profile/d/31718207
b) Listing of Jae Arre Lloyd as legal Agent for Service for Skyline Funding Corp, the same corporation,
where disappearance of ERISA funds were subject of his conviction on felonies under a previous
identity – as Timothy Lloyd Morrow.
• http://www.scribd.com/doc/31718029/09-09-27-Skyline-Funding-Corp-California-Secretary-of-
Corporation-listing-Legal-Agent-for-Service-Jae-Arre-Lloyd-formerly-Timothy-Lloyd-Morrow
[11] Opinion letter by highly decorated FBI veteran James Wedick on the real estate fraud against Dr Joseph
Zernik by Attorney David Pasternak, Nivie Samaan, and others, in Grant Deeds of December 2007.
• http://www.scribd.com/doc/24991238/07-12-17-Samaan-v-Zernik-SC087400-David-Pasternak-Grant-
Deeds-opined-as-fraud-by-James-Wedick-ss
[12] August 2008 email letter by highly decorated FBI veteran James Wedick, documenting his
communications with FBI on the real estate fraud against Dr Joseph Zernik.
• http://www.scribd.com/doc/29713733/08-08-21-Samaan-v-Zernik-SC087400-Email-letter-by-highly-
decorated-FBI-veteran-James-Wedick-regarding-refusal-to-Investigate-FBI-to-provide-Dr-Zernik-
protection-against-real-estate-fraud-s

Page 7/7 May 21, 2010

[13] 2006-7 a set of fraudulent letter and declarations under penalty of perjury, generated by Maria McLaurin
as part of her collusion in the real estate fraud, and as part of cover-up of large scale fraud against the US
government in underwriting at the Countrywide San Rafael Branch, which she managed.
• http://www.scribd.com/doc/30971372/08-04-17-Zernik-v-Connor-et-al-2-08-cv-01550-Dkt-038-
Countrywide-apos-s-McLaurin-False-Declarations-under-Samaan-v-Zernik-SC087400