First Amended Complaint - Gaudin v. Saxon Mortgage Settlement

Transcription

Case3:11-cv-01663-RS Document39
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Filed09/12/11 Page1 of 27
Daniel J. Mulligan (Cal. State Bar No. 103129)
JENKINS MULLIGAN & GABRIEL LLP
10085 Carroll Canyon Road, Suite 210
San Diego, CA 92131
Telephone: 415-982-8500
Facsimile: 415-982-8515
Peter B. Fredman (Cal. State Bar No. 189097)
LAW OFFICE OF PETER FREDMAN
125 University Ave, Suite 102
Berkeley, CA 94710
Telephone: (510) 868-2626
Facsimile: (510) 868-2627
[email protected]
Attorney for Plaintiff MARIE GAUDIN,
for herself and persons similarly situated
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
MARIE GAUDIN, individually, and on behalf )
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of others similarly situated,
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Plaintiff,
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v.
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SAXON MORTGAGE SERVICES, INC. a )
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Texas corporation, and Does 1-100,
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Defendants.
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_____________________________________ )
Case No. C 11-1663 RS
CLASS ACTION
FIRST AMENDED COMPLAINT FOR
DAMAGES AND RESTITUTION FOR
(1) BREACH OF CONTRACT
(COVENANT OF GOOD FAITH AND
FAIR DEALING)
(2) RESCISSION AND RESTITUTION
(CAL. CIVIL CODE §§ 1688, ET SEQ.)
(3) UNFAIR DEBT COLLECTION
PRACTICES (CAL. CIVIL CODE §§ 1788,
ET SEQ.)
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(4) UNFAIR COMPETITION LAW
(CAL.BUS. & PROF. CODE §§ 17200, ET
SEQ.)
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JURY TRIAL DEMANDED
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First Amended Complaint
Gaudin vs. Saxon Mortgage Services, Inc. – C 11-1663 RS
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Plaintiff Marie Gaudin, by and through her attorneys, brings this action on behalf of
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herself and all others similarly situated against the above named Defendants, demands a trial by
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jury, and complains on information and belief as follows:
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INTRODUCTION
1.
This class action lawsuit seeks to redress and remedy Defendant Saxon Mortgage
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Services Inc.’s (Saxon’s) policy and practice of falsely promising its delinquent residential
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mortgage customers like Plaintiff Marie Gaudin and persons similarly situated the opportunity to
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retain their homes through an income-based loan modification program known as the
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Homeowners Affordable Modification Program (HAMP).
2.
Specifically, Saxon offered said persons a HAMP Trial Period Plan (TPP)
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document that appeared to be an enforceable offer to provide said persons with loan
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modifications if they successfully completed a three month trial period and certain conditions
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were met. Saxon thereby collected trial period payments from said persons, when, Plaintiff
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alleges, it did not actually consider the TPP document to be legally enforceable and had no
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intention of honoring it as such. This class action lawsuit addresses, among other things, the
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questions of whether the TPP document was an enforceable agreement and whether Saxon
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committed unfair debt collections practices by using the TPP document to collect trial period
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payments when it had no intention of honoring the promises of the TPP document whether they
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were enforceable or not.
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3.
Beginning in early 2009, Plaintiff sought a modification of the loans secured by
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her residence. She made this request to Saxon. After providing her financial information and all
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other requested documents to Saxon’s “Home Preservation Department,” Plaintiff was offered a
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“trial” HAMP loan modification agreement (a/k/a TPP document) that provided for a reduction
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of Plaintiff’s monthly mortgage obligation to an affordable payment, and promised, in writing, to
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permanently modify the mortgage if she made the required three trial period payments and
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provided any further requested documentation of her financial condition. Saxon’s
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correspondence assured her it was “committed to assisting you in any way we can to complete
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the Agreement. We want to help!” A true and correct copy of this trial modification agreement
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(a/k/a TPP document) is attached hereto as Exhibit B.
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4.
Far from assisting, however, Saxon delayed the processing of the loan
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modification, while urging Plaintiff to continue making trial payments. It then denied her a
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permanent modification without cause, and despite the fact that all the conditions set forth in the
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TPP document were satisfied and Plaintiff qualified for a permanent loan modification under
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objective standards set forth in the HAMP program. Saxon sent Plaintiff several letters
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purportedly explaining why she had been declined for a permanent modification. In these letters,
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Saxon falsely claimed that Plaintiff had failed to make the trial payments and/or supply requested
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documents. When Plaintiff confronted Saxon with the falsity of these statements, Saxon made
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no attempt to back up or explain them.
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5.
Saxon self-reports that more than two-third of its HAMP trial loan modification
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offers never result in permanent HAMP loan modifications starts: i.e., persons who received
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HAMP “trial” agreement offers had, in fact, less than a 33% chance of receiving a permanent
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HAMP modification agreement. Among all servicers, the leading causes of cancellation are
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reported as “insufficient documentation” or “trial plan payment default” – just as Saxon falsely
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asserted was the case with Ms. Gaudin.
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6.
Plaintiff alleges that Saxon has a policy and practice of deliberately or negligently
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failing to convert HAMP trials to permanent loan modifications and falsely claiming
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“insufficient documentation” or “trial plan payment default” as the reason. More broadly,
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Plaintiff alleges that Saxon has a policy and practice of offering “trial” HAMP loan
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modifications that it had no good faith intention or ability to make permanent. It thus deceived
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its distressed mortgage customers into making trial payments – often continued for months
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beyond the designated trial period based on the promise that the loan modification was being
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considered – and then failed and refused to offer permanent loan modifications even though all
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the conditions that obligated Saxon to provide a permanent modification agreement were
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satisfied.
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7.
Plaintiff alleges that she is typical of a class of Saxon customers who received
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trial HAMP loan modifications that Saxon reneged on without cause. On behalf of herself and
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the class, she alleges breach of contract, rescission and restitution, deceptive debt collection
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practices under California’s Rosenthal Fair Debt Collection Practices Act (Rosenthal Act) and
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fraudulent, unlawful, and unfair business practices under California’s Unfair Competition Law
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(UCL).
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PARTIES
8.
Plaintiff Marie Gaudin is a resident of San Mateo County, California at the real
property located at 2203 Wildflower Court, Daly City 94014 (the “Property”).
9.
Defendant Saxon Mortgage Services Inc. (“Saxon”), a Texas corporation, does
business throughout California and has its principal place of business in Fort Worth, Texas.
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JURISDICTION AND VENUE
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10.
This Court has jurisdiction pursuant to the provisions of the Class Action
Fairness Act, 28 U.S.C. § 1332(d) et seq (“CAFA”).
11.
Venue is proper in this Court because defendants’ liability to Plaintiff arose
within the jurisdictional region of this Court, where Saxon does substantial business.
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FACTS
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Plaintiff Marie Gaudin is a single, self-employed, small business woman who has
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operated a San Francisco bridal boutique for over 30 years. She purchased the Property in 1993
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and refinanced several times over the years.
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13.
In or about October, 2006 Plaintiff refinanced with the now-defunct WMC
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Mortgage for approximately $400,000. On information and belief, the mortgage loan was
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eventually acquired by Morgan Stanley as a negotiable instrument and pooled into something
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called “Morgan Stanley ABS Capital I Inc. Trust 2007-HE4”. Saxon, a subsidiary of Morgan
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Stanley, became the servicer of the loan.
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14.
By early-2009, Plaintiff’s business had suffered a severe decline in revenues as a
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result of the steep recession that resulted from the financial crisis that resulted from the conduct
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of large financial institutions like Morgan Stanley and WMC. Plaintiff was not in a position to
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make the full monthly mortgage payment, and the value of the Property had plummeted to far
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less than the subject loan.
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15.
Plaintiff contacted Saxon to request a loan modification, providing it all
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information and documentation that it requested. On April 13, 2009, Saxon denied the initial
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request, as set forth in Exhibit A.
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16.
In that correspondence and other communications, Saxon represented that it had a
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“Home Preservation Team” that “makes every effort to assist our mortgagors whenever
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possible”.
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17.
Despite this initial denial by Saxon, Plaintiff persisted in her efforts to obtain
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relief and, effective June 1, 2009, Saxon offered her a HAMP loan modification “trial plan”
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agreement (i.e. a TPP document), a fully executed version of which is attached hereto as Exhibit
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B.
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18.
The “trial plan” agreement set forth an affordable monthly payment, and provided
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that Plaintiff’s loan would be permanently modified to reduced monthly payments if Plaintiff
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fulfilled the terms of the trial agreement by making the trial payments and providing
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supplemental documentation if requested. Exhibit B, p. 1.
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19.
Plaintiff made all three monthly payments required under the trial plan agreement
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and performed all other conditions required or requested of her during the three month trial
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period. Pursuant to the dictates of HAMP, and the representations in the trial plan agreement,
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she should have been offered a permanent HAMP loan modification effective September 1,
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2009. This did not occur.
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20.
On September 28, 2009, Saxon sent Plaintiff a letter falsely claiming that there
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were “important documentation and/or payments missing in order to qualify for a permanent
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Home Affordable Modification Agreement (‘Agreement’)”. The letter further asserted: “Saxon
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is committed to assisting you in any way we can to complete the Agreement. We want to help!”
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A copy is attached as Exhibit C.
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21.
Plaintiff contacted Saxon as directed in Exhibit C, and was assured that all
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necessary documents had been received. Plaintiff was told to keep making her trial payments
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pending the further processing of her modification. Saxon customer service phone personnel
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repeatedly confirmed that her application was complete and that no further documentation was
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needed from her.
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On December 30, 2009, Saxon sent Plaintiff a form notice from the “Home
Preservation Department” falsely claiming that she had “failed to submit all the required
documentation”. It also claimed “We want to work with you.” A copy is attached as Exhibit D.
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On January 8, 2010, Saxon sent Plaintiff a form letter acknowledging that her trial
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modification period had been completed, but instructing her to continue making the trial plan
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payments anyway while it continued to review her file. A copy is attached as Exhibit E.
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24.
On March 23, 2010, Saxon sent Plaintiff a form letter falsely claiming she “did
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not make all the required Trial Period Payments by the end of the trial period.” This was
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pursuant to a form letter that gave the sender a choice of two boxes to check as the reason for the
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declination, the other option being: “You did not provide us with the documents we requested”.
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A copy is attached as Exhibit F.
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25.
On July 14, 2010, Saxon sent Plaintiff a form letter stating that her “loan was
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removed from HAMP on 3/17/10, because we did not receive all of the required payments” and
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suggesting that she apply for a short sale. A copy is attached as Exhibit G.
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26.
On October 4, 2010, Saxon sent Plaintiff a form letter denying the HAMP
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modification on the false grounds that her “loan was previously modified under [HAMP].” A
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copy is attached as Exhibit H.
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27.
On January 26, 2011, Saxon sent Plaintiff a form letter again falsely claiming that
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she had failed to make payments (while conceding somewhat further down the page of the same
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letter that she “continued to make the trial payments until July 2010”). The letter also falsely
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claimed that the U.S. Treasury was involved in the review of the HAMP application. A copy is
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attached as Exhibit I.
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Throughout this process, Plaintiff persistently communicated with Saxon, orally
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and in writing, explaining that it was not true that she had missed any payments or failed to
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provide any requested documents. In written correspondence and orally, she repeatedly asked
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Saxon to identify which payments it claimed she missed and/or which document requests it
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claimed she failed to fulfill. Saxon never answered in a responsive way, but, rather simply
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persisted in sending her the false form letters as set forth above.
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29.
Plaintiff is informed and believes and on that basis alleges that at the relevant
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times all the conditions that obligated Saxon to provide Plaintiff a permanent modification
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agreement were satisfied and Plaintiff qualified for a permanent loan modification under the
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objective standards set forth in the HAMP program.
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30.
Plaintiff alleges on information and belief that Saxon had internal policies and
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practices (or the absence thereof) that were intended to and did falsely prevent its customers
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from obtaining permanent status in a manner similar to those used to deny Plaintiff a permanent
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modification regardless of whether or not the conditions that obligated Saxon to provide a
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permanent modification agreement were satisfied and regardless of whether or not they qualified
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for a permanent loan modification under the objective standards set forth in the HAMP program
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CLASS ALLEGATIONS
31.
This class action is brought pursuant to Rules 23(a), (b)(2) and (b)(3) of the
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Federal Rules of Civil Procedure by the individual named Plaintiff on behalf of herself and the
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following class:
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All California residential mortgage customers of Saxon who received HAMP trial
loan modification agreements, made the three trial payments required thereunder,
but did not receive such permanent HAMP loan modifications.
32.
Plaintiff does not know the exact size or identities of the proposed Class, since
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such information is in the control of defendants. Plaintiffs believe and allege, however, that the
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Class encompasses approximately 6,000 California residential mortgage borrowers who are
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geographically dispersed throughout California. Therefore, the proposed class is so numerous
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that joinder of all members is impracticable.
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33.
Common questions of fact and law predominate over any questions affecting only
individual members including, but not limited to, the following:
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a. whether Saxon had policies and procedures, or the absence thereof, that caused it
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to erroneously “remove” loans from HAMP processing based on false assertions
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that the borrower had failed to make payments or provide documents;
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b. whether the representations and promises of permanent HAMP modification set
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forth in the HAMP trial agreements and related correspondence were false or
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deceptive;
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c. whether the HAMP trial agreements, such as Exhibit B, were valid and binding
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and whether Saxon had programs in place that constituted material performance
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of the Agreements;
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d. whether Saxon knew or should have known that recipients of the HAMP trial plan
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agreements, such as Exhibit B, would understand and believe them to be
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enforceable agreements;
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e. whether Saxon considered the HAMP trial plan agreements to be enforceable
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and/or intended to honor the promises set forth in the trial plan agreements at the
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time they were offered to its customers;
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f. whether Saxon’s conduct with respect to the HAMP trial agreements subjects the
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agreements to rescission and restitution for failure of consideration under section
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1688 of the California Civil Code;
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g. whether Saxon’s conduct with respect to the HAMP trial agreements constituted
unfair debt collection practices under the Rosenthal Act;
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h. whether Saxon’s with respect to the HAMP trial agreements violated the Unfair
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Competition Law (UCL) and, specifically, whether the representations in the
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HAMP trial agreements and related correspondence were material within the
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meaning of In Re Tobacco II.
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34.
This is a matter of important public policy because foreclosure avoidance, where
possible, and the fair treatment of distressed borrowers are state and national policy priorities.
35.
Plaintiff’s claims are typical of the claims of the Class and do not conflict with
the interests of any other members of the Class.
36.
Plaintiff will fairly and adequately represent the interests of the Class. They are
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committed to the vigorous prosecution of the Class claims and have retained attorneys who are
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qualified to pursue this litigation and have experience in class action and foreclosure claims.
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37.
A class action is superior to other methods for the fast and efficient adjudication
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of this controversy and to avoid the risk of disparate and inconsistent rulings throughout the
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state. Due to the inherent financial condition of the victims of these alleged practices, a class
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action is the only way they have any hope of receiving justice for the practices alleged herein. A
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class action regarding the issues in this case does not create any problems of manageability.
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1ST CLAIM FOR RELIEF
(Breach of Contract/Implied Covenant of Good Faith and Fair Dealing)
(Against Saxon and Does)
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38.
The preceding paragraphs are incorporated by reference.
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39.
Plaintiff entered into the agreement with defendants that is attached hereto and
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incorporated by reference as Exhibit B.
40.
In every contract or agreement, including those at issue here, there is an implied
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promise of good faith and fair dealing, which means that each party will not do anything to
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unfairly interfere with the right of any other party to receive the benefits of the contract.
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41.
Plaintiff performed all her obligations under the agreement except to the extent
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that they were excused from performance, and all the conditions requiring Defendants’
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performance were satisfied.
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42.
Defendants breached the agreement and totally failed to provide the consideration
they promised thereunder.
43.
Plaintiffs were harmed as a result of the breach, and are entitled in the alternative
to damages to terminate the agreement and recover their consideration paid under the Agreement
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(i.e. their forbearance payments) without formal rescission. Richter v. Union Land Co. (1900)
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129 Cal. 367, 372-373; Morrell v. Clark (1951) 106 Cal.App.2d 198, 203.
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WHEREFORE, Plaintiff prays for judgment and relief as set forth below.
2ND CLAIM FOR RELIEF
(Rescission and Restitution – Cal. Civil Code §§ 1688-1689 )
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44.
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45.
NOTICE OF RESCISSION: In the alternative, Plaintiff and putative Class, by
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service of this Class Action Complaint on Defendant Saxon, hereby provide notice to
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Defendant, its subsidiaries, affiliates, and the entities it represents as loan servicer that the
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HAMP trial modification agreements described in this First Amended Complaint are subject to
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rescission and are hereby rescinded for the reasons set forth herein.
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46.
Section 1689(b) of the California Civil Code provides that a “party to a contract
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may rescind the contract … (1) [i]f the consent of the party rescinding … was given by
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mistake, or obtained through duress, menace, fraud, or undue influence, exercised by or with the
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connivance of the party as to whom he rescinds … (2) [i]f the consideration for the obligation of
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the rescinding party fails, in whole or in part, through the fault of the party as to whom he
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rescinds .... (4) [i]f the consideration for the obligation of the rescinding party, before it is
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rendered to him, fails in a material respect from any cause.”
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47.
Plaintiff is entitled to rescind the Agreement under Civil Code § 1689(b) and
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recover her consideration paid there under because her consent to the agreement was given by
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mistake, and/or obtained through fraud exercised by Saxon, and/or because the consideration
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promised by Saxon failed in a material respect through the fault of Saxon.
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48.
to rescission.
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3RD CLAIM FOR RELIEF
(Rosenthal Fair Debt Collection Practices Act – Cal. Civ. Code §§ 1788 et seq.)
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Plaintiff has retained no consideration that must be tendered back to Saxon prior
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50.
Defendants were “debt collectors” engaging in “debt collection” practices under
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the Rosenthal Fair Debt Collection Practices Act (the “Rosenthal Act”). Cal. Civ. Code §
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1788.2(c).
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51.
Defendants violated the Rosenthal Act by using false, deceptive, and misleading
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statements in connection with their collection of the mortgage debts of Plaintiff and persons
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similarly situated, as alleged herein. Cal. Civ. Code § 1788.17, incorporating 15 U.S.C.A. §
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1692e. More specifically:
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a.
Saxon offered TPP documents and entered into apparent HAMP trial plan
agreements with Plaintiff and persons similarly situated knowing (and/or with reckless or
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negligent disregard for the fact) that it (and/or the investors whose owned the loans it serviced)
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did not consider these agreements to be legally enforceable or to impose any obligation on them
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to convert the trial plans into permanent HAMP loan modifications pursuant to these agreements.
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b.
Saxon entered into these HAMP trial plan agreements with Plaintiff and
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persons similarly situated knowing (and/or with reckless or negligent disregard for the fact) that
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Plaintiff and such persons would reasonably understand and believe that these were valid and
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enforceable contracts, that Saxon understood them as such, and that Saxon (and/or the investors
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whose owned the loans it serviced) were thus committing themselves to convert the trial plans
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into permanent HAMP loan modifications pursuant to these agreements if the conditions therein
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were satisfied.
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c.
Saxon falsely represented that it intended to, and had the capability, of
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assisting borrowers obtain permanent, affordable loan modifications through the HAMP
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program, when, in reality, its internal procedures policies and practices, as applied to all such
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borrowers, did not provide the borrowers who received the HAMP trial plan agreements with a
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meaningful opportunity to retain their homes through loan modification regardless of whether or
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not the conditions of the agreement were satisfied or the borrowers qualified under the uniform
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standards of the HAMP program.
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52.
The 1999 Amendment to the Rosenthal Act allows for class actions for violations
to the same extent they are allowed under the federal Fair Debt Collection Practices Act
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(“FDCPA”). Cal. Civ. Code § 1788.17, incorporating 15 U.S.C.A. § 1692k; Gonzales v. Arrow
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Financial Services, LLC, 233 F.R.D. 577, 581 (S.D.Cal.2006).
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4TH CLAIM FOR RELIEF
(Unfair Competition – Cal. Bus. & Prof. Code §§ 17200, et seq.)
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53.
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54.
California’s Unfair Competition Law (the “UCL”) defines unfair competition to
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include any “unlawful, unfair, or fraudulent” business act or practice. Cal. Bus. & Prof. Code §§
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17200 et seq.
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55.
Defendants engaged in “fraudulent” business practices under the UCL because the
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HAMP trial modification offer was intended and likely to mislead the public into believing that
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they could obtain an opportunity to retain their homes if they accepted and complied with the
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terms of the TPP document. A true opportunity to retain their homes was “material” to Plaintiff
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and the class within the meaning of In re Tobacco II Cases (2009) 46 Cal.4th 298, 325.
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56.
Defendants engaged in “unlawful” business practices under the UCL based on the
violation of the Rosenthal Act and based on the common law breach of contract.
57.
Defendants engaged in “unfair” business practices under the UCL because they
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violated the laws and underlying legislative policies designed to (a) prevent foreclosure, where
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possible, by requiring mortgage holders to engage in honest foreclosure prevention efforts (see
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Cal. Civil Code § 2923.5); (b) provide Californians with anti-deficiency protections that prevent
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mortgage holders from seizing other assets or monies of the borrowers after electing to sell the
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security in satisfaction of the mortgage debt (see C.C.P. § 580d, § 726); and (c) allow contracting
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parties to enjoy the benefits of their agreement after paying valuable consideration therefore.
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58.
Plaintiff and the Class were injured in fact and lost money or property as a result
of these unlawful, unfair, and fraudulent business practices.
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///
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PRAYER FOR RELIEF
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WHEREFORE, Plaintiffs request judgment as follows:
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A.
An order certifying the Plaintiff Class, appointing the named Plaintiff as the
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representative of the Class, and appointing the law firms representing the named Plaintiff as
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counsel for the Class.
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B.
An order rescinding and/or terminating the HAMP trial modification agreement of
each member of the Class who so elects and restitution of the consideration paid by Plaintiff and
the Class under the HAMP trial modification agreements;
C.
Damages for each class member who qualified for permanent HAMP loan
modification as measured by the present value of the permanent modification option at the time
they should have received it.
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D.
Class wide statutory damages under the Rosenthal Act, as it incorporates the
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remedies provisions of the FDCPA, 15 U.S.C. § 1692k, pursuant to section 1788.17 of the
California Civil Code. See Gonzales v. Arrow Financial Services, LLC 233 F.R.D. 577, 581
(S.D.Cal.,2006).
E.
Such additional orders or judgments as may be necessary to prevent these
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practices and to restore to any person in interest any money or property which may have been
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acquired by means of the UCL violations.
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F.
Attorneys’ fees, costs, and expenses pursuant to the Rosenthal Act, section 1021.5
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of the Code of Civil Procedure, and pursuant to Paragraph 22 of the standard Plaintiff’s Deed of
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Trust as rendered mutual by section 1717 of the California Civil Code.
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G.
And for such other and further relief as the Court may deem proper.
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DATE: September 12, 2011
JENKINS MULLIGAN & GABRIEL LLP
By: /s/ Peter Fredman
PETER FREDMAN,
Attorney for Plaintiff,
MARIE GAUDIN
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DEMAND FOR JURY TRIAL
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Plaintiff requests a jury trial on all claims so triable.
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By: /s/ Peter Fredman
PETER FREDMAN,
Attorney for Plaintiff,
MARIE GAUDIN
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Exhibit A
Exhibit B
Exhibit B
Exhibit B
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit H
Exhibit I

First Amended Complaint - Gaudin v. Saxon Mortgage Settlement

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