Bank of New York Mellon v. Chase

CourtSuperior Court of Maine
DecidedFebruary 17, 2016
DocketCUMre-13-03
StatusUnpublished

This text of Bank of New York Mellon v. Chase (Bank of New York Mellon v. Chase) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of New York Mellon v. Chase, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS. CIVIL ACTION Docket No. RE-13 -03

STATE OF MAINE BANK OF NEW YORK MELLON, ·Cumberland. st. Clerk's Offioo as Trustee FEB 2 2 2016 Plaintiff RECEIVED v. ORDER

KAREN CHASE, et al.

Defendants

Before the court is a request for sanctions by defendants. A hearing on that issue was held

on December 4, 2015, at which plaintiff was represented by counsel 1 and at which for the first

time counsel appeared for defendants Karen and Colin Chase. The Chases had previously been

unrepresented. Further argument on the issue of sanctions was offered at a hearing on February

17, 2016.

At that hearing the court ordered that N ationstar Mortgage LLC be substituted as the

plaintiff and determined that if any sanctions were imposed, they would be imposed on

Nationstar without prejudice to Nationstar's right to seek contribution or indemnity from BNY

Mellon or its servicer, Bank of America. See order dated February 17, 2016. I As discussed below, the ownership of the loan was transferred from BNY Mellon to Nationstar during the course of these proceedings . However, no formal motion to substitute Nationstar as the plaintiff had been filed as of December 4. On that date, Christine Johnson from the Schechtman Halperin firm, which had previously represented BNY Mellon, appeared to discuss the pending loan modification and to oppose sanctions. The court understood that Ms . Johnson at that time was representing both Nationstar and BNY Mellon. On the issue of sanctions Ms. Johnson did not draw any distinction between Nationstar and BNY Mellon but opposed sanctions both for the time period before Nationstar entered the picture and afterward . Ultimately the court raised the issue of whether Nationstar should be formally substituted as plaintiff and whether any sanctions should somehow be apportioned between BNY Mellon (and/or its servicer Bank of America) on the one hand and Nationstar on the other. That led to the court's order of December 8, 2015 giving counsel time to consider the issue . The Schechtman Halperin firm then moved to withdraw. See order of December 17, 2016 . There have been eight mediations in this case and two notices of noncompliance. After

the third mediation the mediator issued a report of non-compliance based on a failure by the

servicer (Bank of America) to meet an agreed timeline for responding to a loan modification

request submitted by the Chases. The court did not take action at that time because it appeared

that the issue had been resolved based on a February 19, 2014 letter from plaintiff's counsel. See

March 3, 2014 order. The notice of noncompliance, however, remained open.

What the court did not know when it issued its March 3 order was that the Bank of

America had sent a February 27, 2014 letter to the Chases stating that their application for a

modification was no longer being considered because Bank of America had not received

documents it had requested - even though it had been agreed at a prior mediation that everything

necessary had been submitted. Within a short time counsel for plaintiff stated that Bank of

America's February 27 letter had been sent "in error." The Chases, however, were fully entitled

to feel whipsawed.

By the time of a fourth mediation held in April 2014 Bank of America had issued a denial

of the Chase's application for a modification (apparently wrongly, as it turned out), and the

Chases were advised of their right to appeal the denial.

At a fifth mediation in June 2014 the Chases were informed that Bank of America was

claiming that their appeal had been filed too late. However, the Chases were able to prove that

was incorrect. The error was attributed to a breakdown in the Bank's internal processes (see

report of fifth mediation), and Bank of America agreed to process the Chase's appeal. This

sequence of events, however, was a second instance in which the Chases were whipsawed and

likely contributed to any anxiety they faced at the possibility of losing their home.

2 At a sixth mediation in September 2014 the parties reported that after the appeal had been

processed, a loan modification had been offered with a three month trial period before the loan

modification would become final.

The trial period was successful and the final loan modification was signed by the Chases

and forwarded to Bank of America for execution in December 2014. See Report of 7th

Mediation on January 9, 2015. However, it was reported at the January 9, 2015 mediation that

the servicing of the loan had been transferred to Nationstar earlier and that Nationstar - in

apparent ignorance of the loan modification agreement that had been reached with Bank of

America - had sent notices to the Chases asserting that they were in default. This was the third

instance of the Chases being whipsawed in the course of the mediation process and likely caused

the Chases to experience further anxiety and distress - as noted in the report of the January 9,

2015 mediation. By the time of that mediation, however, it appeared that the appropriate

documentation was in the process of being provided to Nationstar, and it was understood that the

permanent loan modification would be placed into effect.

On February 25, 2015 counsel for plaintiff filed a motion to dismiss this action without

prejudice stating that their client had informed them that the loan had been modified and the

default had been cured.2 Given the status of the case the court did not act on that motion - which

has been adopted by Nationstar and is still pending - and awaited developments.

By the time of an eighth mediation on March 27, 2015 , the Chases had not received an

executed modification back from Nationstar or from anyone else. Given the delay attributable to

the Bank of America and to Nationstar in consummating the permanent modification, the

mediator issued a second notice of noncompliance.

2 Notably, counsel also simultaneously submitted a proposed order declaring that the previous order of noncompliance was now moot - demonstrating awareness that the court's March 3, 2014 order had not resolved that issue.

3 On or about March 25, 2015, apparently unbeknownst to counsel for plaintiff and the

Chase at the time, the loan itself - not just the servicing - was transferred to Nationstar. The

Chases later received a notice to that effect dated May 19, 2015 .

Around that same time the Chases advised the court that they had received loan

modification documents from Nationstar but that it appeared to them that those documents made

changes from the prior loan modification agreement. 3 The Chases asked for sanctions up to and

including dismissal with prejudice.

In opposition to the Chase's motion for sanctions, counsel for plaintiff submitted emails

that had been sent to the Chases assuring them that the agreement was not being unilaterally

modified and suggesting a meeting or discussion to resolve any issues. The court understands

that the Chases, perhaps understandably in light of the history of this case, had declined to

respond to those emails.

Because it appeared that an agreement had in fact been reached, because the court was

prepared to enforce that agreement on behalf of the Chases, because of the efforts made by

counsel for plaintiff to resolve the situation, and because the most recent delay appeared to result

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