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STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE

CREDIT-BASED ASSET SERVICING AND SECURITIZATION, LLC

-against-

Plaintiff,

MARSHA PILLICH, et. al.

Defendants.

STATE OF TEXAS

)

ss)

COUNTY OF HARRIS

)

Index No. 2003-2388

AFFIDAVIT OF CHRISTOPHER A. WYATT

I, CHRISTOPHER A. WYATT, being first duly sworn, deposes and says as

follows:

1. My name is Christopher A. Wyatt, and I currently reside at 406 Spring Lakes

Haven, Spring, Texas 77373. I have personal knowledge of the facts stated in

this

affidavit

based

on

my

personal

knowledge

and

experience.

The

statements contained herein are true and correct.

If called upon, I would be

willing to testify in court as to these matter.

2. On November 5, 2011, Plaintiff engaged to related to a review mortgage

documents as well as certain affidavits relating to the summary judgment

motion seeking a judgment of foreclosure relating to certain real property

commonly known as, 8 Eltham Drive, Amherst, NY 14226 (the “Subject

Property”).

Qualifications

3. I currently offer services as a consultant and/or as an expert in the field of

mortgage loan servicing through my company, Wyatt Consulting Services.

4. A true and correct copy of my curriculum vitae is attached hereto, Marked

Exhibit “A”, and incorporated by reference.

5. 3.

To summarize my qualification and expertise, I have over 20 years of

experience in the residential mortgage loan servicing industry beginning with

my employment at Bank United where I worked from October 1987 to May

2000, to Litton Loan Servicing (“Litton”) where I was employed from June

2001

to

April

2010,

and

then

to

my present

employment with

Wyatt

Consulting Services that began on May 2010.

6. 4.

During my employment with Litton, I served in the position of Vice

President Litigation and Executive Resolution; however, I am not an attorney.

Documents Reviewed

7. I reviewed the following documents:

a. Affidavit of Helen Steels, a true and correct copy of which is attached

hereto as Exhibit “B”.

b. Affidavit of Jackie Houston, a true and correct copy of which is attached

hereto as Exhibit “C”.

Assistant Vice President of Nationscredit Financial Services Corporation,

a true and correct copy of which is attached hereto as Exhibit “D”.

d. LINKEDIN.COM public employment resume published by George Knight.

Affidavit of Helen Steels

8. The affidavit of Helen Steels does not contain an execution date.

9. Although the notary merely indicates that Ms. Steele’s affidavit was executed

on or about July 23, 2003, it has been my experience while working at Litton

that these types of affidavits were not executed in the presence of the a notary.

10. More importantly, the affidavit indicates that Ms. Steele is an authorized agent

of the Plaintiff, Credit Based Asset Servicing and Securitization LLC (“C-

Bass”), and that her knowledge is based on an examination of the records of

C-Bass.

11. From working at Litton, I know that C-Bass limited the number of Litton

officer’s to act as an authorized representative through a Limited Power of

Attorney. However, there is nothing in Ms. Steele’s affidavit stating that Ms.

Steele was an authorized representative acting on C-BASS’s behalf through a

limited power of attorney.

12. There is no indication by C-BASS or Ms.

Steele that Ms. Steele was

authorized to execute this affidavit on behalf of C-Bass.

Based on my

experience with while working at Litton, Ms. Steele did not have authority.

13. Furthermore, C-Bass was not servicing the loan for the Subject Property, thus

it did not maintain the appropriate records with this Litton servicer.

Based

upon my direct knowledge as to Litton’s internal procedures concerning

Litton’s litigation support, it is my opinion that Ms. Steele could not have

reviewed any records maintained by C-Bass to support her affidavit in this

action.

14. Finally, it has been my experience that Litton representatives during this time

period

did

not

actually

review

the

underlying

loan

information

(e.g.,

computing amounts due and owing) prior to or after the execution of any

affidavits.

Affidavit of Jackie Houston

15. As with the affidavit of Helen Steele, the affidavit of Jackie Houston does not

contain an execution date. (see “Exhibit B”)

16. Although the notary merely indicates that the affidavit was executed on or

about January 4, 2004, it has been my experience that these types of affidavits

were not likely executed in the presence of the a notary.

17. More importantly, the affidavit indicates that she is an authorized agent of the

C-Bass, and that her knowledge is based on an examination of the records of

C-Bass.

18. C-Bass limited

the

number

of Litton

officer’s to

act

as

an authorized

representative through a Limited Power of Attorney. However, there is nothing

in Ms. Houston’s affidavit stating that Ms. Houston was an authorized

representative acting on C-BASS’s behalf through a limited power of attorney.

19. There is no indication by C-BASS or Ms. Houston that Ms. Houston was

authorized to execute this affidavit on behalf of C-Bass.

Based on my

experience with while working at Litton, Ms. Houston did not have any

authority.

It is my opinion, that Ms. Houston could not have reviewed any

records maintained by C-Bass in order provide any information concerning the

loan in her affidavit.

20. Finally, it has been my experience that Litton representatives during this time

period

did

not

actually

review

the

underlying

loan

information

(e.g.,

computing amounts due and owing) prior to or after the execution of any

affidavits.

Assignment Allegedly Authorized by George Knight

21. I based my opinion on my review of this 12/31/02 assignment of the Pillich

Note related to the endorsements on the Note and the Assignment of Mortgage

and George Knight’s published work resume.

22. C-Bass filed a recorded document in Erie County Clerks office in Jan 19,2003

of an Assignment of Mortgage, dated December 31, 2002, executed by George

Knight, as Assistant Vice President of AAMES Capital Corporation.(“Exhibit

D”)

However,

a

public

work

resume

filed

by

George

Knight

himself(see”Exhibit

E”)

portrays

George

Knight’s

entire

work

career

published with LINKEDIN.com, a national internet recruiting search firm, as

being employed solely by AAMES Home Loan as

a collateral control

manager from 1996 through 2003, not as an officer of either AAMES Capital

Corporation or AAMES Home Loan. This is strong evidence

that someone

including George Knight was working collateral control and in the right place

at the right time to

assist in

falsifying signatures and may not have been an

officer of AAMES Capital Corporation.

23. The Assignment of Mortgage is stamped as notarized by R.P. Umali.

24. Based on my review of this Assignment, it is my opinion, that the Notary

signature was forged on this assignment.

25. In support of this opinion, I reviewed three (3) separate assignments that were

executed by R.P. Umali. (see “Exhibit D”)

26. Based on my review of the signatures on these assignments, it is my opinion,

that the Nationscredit Financial Services Corporation Assignment of Mortgage

was not notorized by R.P. Umali.

27. Furthermore, the Nationscredit Financial Services Corporation assignment

conveys title to a mortgage, dated May 19, 1999. The mortgage at issue in this

case

was dated May 12, 1999.

As

assignment

is

invalid

by

reason

a result,

of

the

it

is my opinion, that this

forgery

and

AAMESofficer

impersonation that is a massively re-occurring crime in the mortgage industry

known as a robo-signed document.

All of the above statements are true and correct and stated as facts based upon my

own personal knowledge.

CHRISTOPHER WYATT, Affiant

Sworn to and subscribed before me on this the

day of

Notary Public My Commission Expires:

,

2011.