Bath Savings Institution v. Elichaa

CourtSuperior Court of Maine
DecidedSeptember 19, 2014
DocketCUMre-13-0445
StatusUnpublished

This text of Bath Savings Institution v. Elichaa (Bath Savings Institution v. Elichaa) 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
Bath Savings Institution v. Elichaa, (Me. Super. Ct. 2014).

Opinion

f 1\J T fRED SEP 2 i 2014

STATE OF MAINE SUPERJOR COURT CUMBERLAND, ss. Docket No. RE-13-0445 CUh'l-RAC- D+ltt-\4- BATH SAVINGS INSTITUTION, Plaintiff

SUZAN_M. ELICHAA, Defendants

BATH SAVINGS INSTITUTION, F.W. WEBB COMPANY, MAINE REVENUE SERVICE, and UNITIL d/b/a NORTHERN UTILITIES ME GAS, Parties-in-interest

Before the Court is a motion by the Plaintiff, Bath Savings Institute, for summary

judgment in a residential foreclosure action brought pursuant to 14 M.R.S. §§ 6321-6325

(20 13 ). 1 Neither the Defendant nor any of the parties-in-interest submitted an opposition the

Plaintiffs motion. However, because the Plaintiff failed to provide evidence of a properly

served notice of default and mortgagor's right to cure in compliance with statutory requirements

and failed to establish the amount due on the note, the motion for summary judgment is

DENIED. See Bank of Am., N.A. v. Greenleaf, 2014 ME 89, ~ 18, --- A.3d ---(citing to Chase

Home Fin. LLC v. Higgins, 2009 ME 136, ~ 11, 985 A.2d 508). Furthermore, the evidence

submitted in support of th_e Plaintiffs motion for summary judgment demonstrates that it lacks

standing to seck foreclosure of the Defendant's mortgage, and thus, the Plaintiff has sixty (60)

days to join the real pa11y-in-interest pursuant to M.R. Civ. P. 17(a) and to provide documentary

evidence of its role as servicer of the mortgage.

1 In addition to the mortgage the Plaintiff is attempting to foreclose in this action, which secures a note given to the Plaintiff for the amount of $286,800, the Plaintiff also claims to hold a second priority mortgage securing a note given to the Plaintiff for the amount of $71,000. (

I. Summary Judgment

The Plaintiffs motion for summary judgment is subject to Rule 56U), which imposes

detailed requirements for granting summary judgment in foreclosure actions. M.R. Civ. P.

56U). 2 The court is independently required to determine ifthose requirements have been met and

is also required to determine whether the mortgage holder has set forth in its statement of

material facts the evidence necessary for a judgement in a residential mortgage foreclosure. See

Greenleaf, 2014 ME 89, ~ 18, ---A. 3d ---; Higgins, 2009 ME 136, ~ 11, 985 A.2d 508.

After reviewing the Plaintiffs motion and the documents and affidavits cited to, the

Court concludes that the requirements for a judgment of foreclosure have not been met, in part

because the Plaintiff failed to produce evidence of a properly served notice in compliance with

14 M.R.S. § 6111 (2013). See Greenleaf, 2014 ME 89, ~ 18,--- A.3d ---(citing to Higgins, 2009

ME 136, ,] II, 985 A.2d 508) (listing the elements of proof necessary to support a judgment of

foreclosure).

The notice referred to and appended to the Plaintiffs motion for summary judgment does

not strictly comply with the requirements of 14 M.R.S. § 6111. The notice, which is dated

September 30, 2013, informs the Defendant that "[a]dditional interest continues to accrue on the

Note at the current rate ... for each day subsequent to September 30, 2013 until you cure your

default." (Pl. SMF ~ 11; Hennessey Af. ~ 18; PI. Ex. C.) The notice also provides that "you will

2 Maine Rule of Civil Procedure 56U) states, in part:

No summary judgment shall be entered in a foreclosure action filed pursuant to Title 14, Chapter 713 of the Maine Revised Statutes except after review by the court and determination that (i) the service and notice requirements of 14 M.R.S. § 6111 and these rules have been strictly performed; (ii) the plaintiff has properly certified proof of ownership of the mortgage note and produced evidence of the mortgage note, the mortgage, and all assignments and endorsements of the mortgage note and the mortgage; and (iii) mediation, when required, has been completed or has been waived or the defendant, after proper service and notice, has failed to appear or respond and has been defaulted or is subject to default.

2 (

... be obligated to pay all additional accrued interest, fees, including attorney's fees, costs and

other expenses incurred by BSI subsequent to September 30, 2013." (Pl. SMF ~ 11; Hennessey

Af. ~ 18; Pl. Ex. C.) These statements do not strictly comply with the statutory requirements of

14 M.R.S. § 6111, which "effectively freezes" additions to the amount necessary to cure the

default. Greenleaf, 2014 ME 89, ~ 31, --- A.3d ---. By stating that the Defendant "will also be

obligated to pay'' additional amounts that accrue on the note subsequent to September 30, 2013,

the notice indicates an amount in excess of the amount listed in the notice will be necessary in

order to cure the default. This runs afoul of 14 M.R.S. § 6111.

Additionally, the amount the Plaintiff asserts is due on the note in its statement of

material facts is not supported by the documents cited to. The Plaintiff claims that $253,727.20

is due and owing on the note. (Pl. SMF ~ 14.) The Plaintiff cites to a "Loan Payoff Statement"

which states the amount due and owing is $253,721.20. (Pl. Ex. I.) A review of the figures

reveals that the "Mortgage Discharge Fee" is only sixteen dollars in the loan payoff statement

but the Plaintiff is claiming it is twenty-two dollars in its statement of material facts. (Pl. SMF ~

14; Pl. Ex. 1.) Although this is a seemingly small discrepancy, it alone would be sufficient to

deny the Plaintiffs motion for summary judgment. See Bangor Sav. Bank v. Richard, 2014 ME

20, ~ 9, 86 A.3d 1167; HSBC Bank USA, N.A. v. Gabay, 2011 ME 101, ~ 9, 28 A.3d 1158

(stressing the importance of applying the rules of summary judgment strictly in foreclosure

ACtions).

Additionally, the Plaintiffs statement of material fact establishing the amount of attorney

fees incurred thus far is not properly supported. The Plaintiff claims to have incurred $6,252.87

in legal fees. (Pl. SMF ~ 22.) However, instead of citing to counsel's affidavit and the billing

records attached to counsel's affidavit, the Plaintiff cites only to the affidavit of its employee

3 who does not reference any supporting documentation. (Hennessey Af. ~ 29.) See M.R. Civ. P.

56(h)(4); Gabay, 2011 ME 101, ~ 8, 28 A.3d 1158 ("The court is neither required nor permitted

to independently search a record to find support for facts offered by a party."). Without a

reference to a breakdown of the legal fees and charges incurred it impossible for the Court to

evaluate whether the legal fees are reasonable, which is especially important in this case given

the unusually high fees incurred in a relatively short period of time. See 14 M.R.S. § 6322

(providing the Court is to determine the amount due on the note, including reasonable attorney

fees).

For these reasons, the Plaintiffs motion for summary judgment is DENIED.

II. Standing

In order to have standing to foreclose a residential mortgage, the Plaintiff must establish:

(1) that it is the holder of the note; and (2) that it is the owner of the mortgage. Greenleaf, 2014

ME 89, ~~ 10-17, --- A.3d ---. The Plaintifffailed to satisfy both prongs ofthe standing analysis

in this case.

Although the Plaintiff need not be the owner, or economic beneficiary, of the note in

order to having standing to foreclose, the Plaintiff must establish that it is the current holder of

the note and is entitled to enforce the note under Maine's Uniform Commercial Code. !d.~~ lO-

ll, 21; US.

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