Summary of Complaints Filed with
State and Federal Regulatory Agencies
11 April 2011
In September 2010, Legal Morass began complaining to various state and federal agencies about the
allegations of fraud committed by various parties relative to a $200,000,000 judgment portfolio sold by
Chase Bank to a debt buyer/collector located in Louisiana, DebtOne.
In April 2011, Legal Morass expanded upon its complaints by supplying 60 MB of evidence to various
state Attorneys General and federal regulatory agencies.
The evidence was freely submitted and delivered to Legal Morass on or about 20 December 2011. It
was delivered and submitted to us without any restrictions upon use, dissemination or distribution,
The submitted evidence contained personally identifiable consumer information. Legal Morass digitally
redacted all personally identifiable consumer information from the evidence prior to submission to state
and federal agencies.
The List of State and Federal Agencies of Filed Complaints
1. Submission of evidence by Legal Morass in February 2011 to the Enforcement and Compliance
Division of the Comptroller of the Currency.
2. Complaint filed by C. Thacker, Legal Morass with the Consumer Financial Protection Bureau.
3. Complaint filed by C. Thacker, Legal Morass with The Federal Trade Commission.
4. Complaint filed by C. Thacker, Legal Morass with the State of California Attorney General.
5. Complaint filed by C. Thacker, Legal Morass with the State of Florida Attorney General.
6. Complaint filed by C. Thacker, Legal Morass with the State of Illinois Attorney General.
7. Complaint filed by C. Thacker, Legal Morass with the State of Louisiana Attorney General.
8. Complaint filed by C. Thacker, Legal Morass with the State of New York Attorney General.
9. Complaint filed by C. Thacker, Legal Morass with the State of Ohio Attorney General.
10. Complaint filed by C. Thacker, Legal Morass with the State of Texas Attorney General.
The Parties Complained About
1. JP Morgan Chase
2. Chase BankCard Services, Inc.
3. Chase Bank USA, NA
4. Sherman Financial
5. DebtOne LLC, a wholly owned subsidiary of Sherman Financial
6. National Loan Exchange, Inc.
7. Keith Schuck, President of Chase Bank USA, NA
8. Suzanne Middleton, CFO of Debt One, LLC
9. Brian K. Bonner, Operations Manager, Chase BankCard Services, Inc.
10. Frank Borchert, Senior Vice-President and General Counsel, Chase BankCard Services, Inc.
11. Jason Lazinbat, Custodian of Records, JP Morgan Chase Bank, NA
12. Charlie Bonner, Chase BankCard Services, Inc.
13. Edmond Helaire, Chase BankCard Services, Inc.
14. Gail Siegal, Esq., Attorney for JP Morgan Chase Bank, NA
15. Martin Murphy, Esq., Attorney for JP Morgan Chase Bank, NA
16. Kimbery A. Rodriguez, Chase BankCard Services, Inc.
17. Brad Layton, Esq., Attorney for JP Morgan Chase Bank, NA
18. Debrorah A. Hicks, Chase BankCard Services, Inc.
19. John C. Simons, Chase BankCard Services, Inc.
20. Debbie Mixon, Chase BankCard Services, Inc.
21. Tony Spencer, Vice President of Sales, National Loan Exchange, Inc.
22. Rochelle Riggins, Chase BankCard Services, Inc.
23. Ruben Alcaraz, Chase BankCard Services, Inc.
24. Kevin Fletcher, Chase BankCard Services, Inc.
25. Allen Soles, Chase BankCard Services, Inc.
26. Quania Randolph, Chase BankCard Services, Inc.
27. Christina Pas, Chase BankCard Services, Inc.
28. Lynn Rodden, Chase BankCard Services, Inc.
29. Dorothia Dembo, Chase BankCard Services, Inc.
30. Kathy Lynn, Chase BankCard Services, Inc.
31. Unknown Individuals
32. Unknown Entities
The Complaint Summaries
As outlined within SEC Whistle-blower complaint included on the CD accompanying the complaintsand
incorporated within the complaints, Linda Almonte was employed by JP Morgan Chase within their
Credit Card Litigation Department. Ms. Almonte was responsible for review and due diligence of a 200
million dollar, face value, Chase post-judgment portfolio that Chase was compiling for bid and eventual
sale to third-parties.
During Ms. Almonte’s due diligence of this portfolio, she uncovered numerous discrepancies as outlined
within both SEC Whistle-blower complaint and the Almonte Affidavit included on the CD accompanying
the complaints and incorporated therein. Not only were discrepancies within the actual amounts
claimed by Chase uncovered, but destruction of consumer records was performed along with massive
‘robo-signing’ of affidavits to support Chase’s sale of this judgment portfolio inclusive of incorrect
balances claimed to be owed by the consumers.
The above named parties knew of such issues (the evidence included on the CD accompanying the
complaints and incorporated therein), willingly participated in such issues, continued in their quest to
sell this portfolio after being informed of such issues, executed documents within state courts as
attorneys-of–record in thousands of cases comprised within this portfolio with full knowledge of these
defects and have further colluded to obstruct state courts, commit fraud upon state courts and obstruct
due process and commit fraud upon consumers listed within the $200MM Chase/DebtOne post-
The harm done to state courts is massive not only financially wherein filing fees paid to the courts do
not cover all direct and indirect costs to process and manage such complaints/law suits but has caused
substantial irreparable harm to the reputation and integrity of the state courts. It has been done with
intent by the above mentioned parties for the sole purpose to affect profit regardless of law, rules of
civil procedure, and by the duty of those Chase attorneys who as officers of the court have willingly and
knowingly failed to uphold the integrity of the state courts and have willfully with full knowledge and
intent participated in such fraud.
National Loan Exchange knew of the defects within this judgment portfolio and served as broker for the
portfolio sale transaction. DebtOne seemed to appear out of nowhere to purchase the portfolio at an
inordinately low price of 1.2¢ on the dollar of the face value of the judgment portfolio. DebtOne was
required to carry an unusually high amount of insurance of $2,000,000 dollars per account for each of
the approximately 23,000 accounts contained within the portfolio. DebtOne processed thousands of
‘robo-signed’ affidavits supplied by Chase to support DebtOne’s claims of assignment and ownership of
accounts within thousands of court cases. Many of the accounts lacked documentation, lacked the
actual judgment, had false amounts stated, had been paid by consumers, had been settled by
consumers prior to portfolio sale, included robo-signed affidavits, included fraudulent assignments and
documents by Chase attorneys, etc., within these cases filed against consumers by DebtOne. DebtOne
was not licensed as either as a foreign corporation in states wherein it was trying to collect upon these
accounts or licensed as a debt collector in jurisdictions that required such licensor.
11 April 2011
Digitally signed by Legal Morass
DN: cn=Legal Morass, o=Legal Morass, ou,
Date: 2011.04.11 15:28:03 -04'00'
Springfield OH 45503