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IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IGNACIO DAMIAN FIGUEROA, on behalf of himself and others similarly situated, Case No. Plaintiff, v. MERSCORP, INC., a foreign corporation; LAW OFFICES OF DAVID J. STERN, P.A., a Florida professional association; and DAVID J. STERN, individually, Defendants. _______________________________________/ COMPLAINT Comes now the Plaintiff, Ignacio Damian Figueroa, on his own behalf and on behalf of others similarly situated, and sues the Defendants, Merscorp, Inc., the Law Offices of David J. Stern, P.A., and David J. Stern, individually, as follows: The Nature of the Action 1. This is an action for triple damages, costs and attorney fees under 18 U.S.C. CLASS ACTION COMPLAINT JURY TRIAL DEMANDED
§§1962 and 1964, otherwise known as the “Racketeer Influenced and Corrupt Organizations Act” or “RICO.” 2. The Named Parties Ignacio Damian Figueroa is the Plaintiff. He brings suit as Class Representative. He
has standing to sue in that capacity because he possesses the same interest and suffered the same type of injury as all other Class Members. 3. Defendant Merscorp, Inc., is a foreign corporation created in or about 1998 by
conspirators from the largest banks in the United States in order to undermine and eventually eviscerate long-standing principles of real property law, such as the requirement that any person or
Case 0:10-cv-61296-CMA Document 1
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entity who seeks to foreclose upon a parcel of real property: 1) be in possession of the original note and mortgage and 2) possess a written assignment giving he, she or it actual rights to the payments due from the borrower pursuant to the mortgage and note. Defendant Merscorp, Inc., claims to be the sole shareholder in an entity by the name of Mortgage Electronic Registrations Systems, Inc., (“MERS”). MERS is the... [continues]
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