Federal National Mortgage Assn v. Lathrop

CourtSuperior Court of Maine
DecidedSeptember 9, 2014
DocketCUMre-13-264
StatusUnpublished

This text of Federal National Mortgage Assn v. Lathrop (Federal National Mortgage Assn v. Lathrop) 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
Federal National Mortgage Assn v. Lathrop, (Me. Super. Ct. 2014).

Opinion

£NT£ RED SEP 2 4 2014

STATE OF MAINE DISTRICT COURT CUMBERLAND, ss. Location: PORTLAND Docket No. RE-13-264 wm-- PJu- -Lft -rJf-l y- FEDERAL NATIONAL MORTGAGE ASSOC., Plamtiff ORDER ON MOTION FOR v. SUMMARY JUDGMENt C:,-c}:>~ '~.

REBECCA A. LATHROP, SEP 09 2014 Defendant

Before the Court is Plaintiffs (Federal National Mortgage Association (FNMA)), for

Motion for Summary Judgment in an action for foreclosure brought pursuant to 14 M.R.S. §§

6321-6325 (2013) against the Defendant, Rebecca A. Lathrop. Defendant did not file a response

to the Plaintiffs Motion nor has she defended against or appeared in the matter. However,

because FNMA failed to establish or provide evidence of ( 1) a breach of condition in the

mortgage, (2) the amount due on the note, (3) the order of priority, (4) evidence of a properly

served notice in compliance with 14 M.R.S. § 6111 (2013), (5) proof of completed mediation or

waiver, and (6) whether or not the defendant is in the military, the motion for summary judgment

is denied. See Chase Home Fin. LLC v. Higgins, 2009 ME 136, ~ 11, 985 A.2d 508.

Furthermore, the mortgage and assignment produced by FNMA demonstrate that it lacks

standing to pursue the foreclosure of the subject property, see Bank of Am., NA. v. Greenleaf,

2014 ME 89, ~~ 12-17, --- A.3d ---, and is not the real party-in-interest. As such, FNMA has

sixty (60) days to join or substitute the real party-in-interest or the case will be dismissed without

prejudice. Plaintiffs motion for summary judgment is subject to Rule 56(j), which imposes detailed 1 requirements for granting summary judgment in foreclosure actions. M.R. Civ. P. 56U). The

Court is independently required to determine if those 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 summary judgment in a residential mortgage foreclosure. See

Higgins, 2009 ME 136, ~ 11, 985 A.2d 508.

After reviewing the Motion and affidavits· cited to, the Court concludes that the

requirements for a summary judgment have not been met because there remains a genuine issue

of material fact regarding six of the elements necessary to support a judgment of foreclosure and

sale. See Greenleaf, 2014 ME 89, ~ 18, --- A.3d ---(citing to Higgins, 2009 ME 136, ~ 11, 985

A.2d 508) (listing the elements of proof necessary to support a judgment of foreclosure).

First, FNMA has not demonstrated that the affiant, Shawann Hampton, is qualified to

introduce records regarding Lathrop's default or the amount due on the note. See M.R. Evid.

803(6); M.R. Civ. P. 56(e); Beneficial Me., Inc. v. Carter, 2011 ME 77, ~~ 14-16, 25 A.3d 96;

(Hampton Af. ~~ 5, 7, 8). FNMA was not assigned the mortgage until March 25, 2013, after

Lathrop allegedly defaulted in December 2011. (Pl. SMF ~~ 6,7; Hampton Af. ~~ 4, 5.) It is

unclear from the record when FNMA began keeping its own records of Lathrop's payments and

the extent to which Hampton is relying on records that were created by entities other than

1 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 FNMA. Hampton's averment that it is the "regular practice of all previous holders and servicers

of the [n]ote and [m]ortgage referenced to make and keep such records in maintaining the

account" is insufficient to admit documents created by other entities or documents created by

FNMA that integrate information contained in documents received from other entities. See

Carter, 2011 ME 77, ~~ 14-16, 25 A.3d 96. Hampton does not identify the previous "holders

and servicers" from which FNMA has received records or provide any foundation for his

assertions that these entities kept the records in their "regular practice." (Hampton Af. ~ 1.) Nor

does Hampton aver that the documents were accurately kept by these prior entities or provide

any details regarding how the documents were integrated into FNMA' s records and checked for

accuracy. Thus, Hampton's affidavit is insufficient to support the admission of the documents

demonstrating Lathrop's alleged default or the amount due on the note and, by extension, any

averments Hampton makes regarding those issues. See Higgins, 2009 ME 136, ~ 11, 985 A.2d

508; HSBC Mortg. Serv. v. Murphy, 2011 ME 59,~ 9, 19 A.3d 815 (emphasizing that a party's

assertion of material facts must be supported by record references that are of a quality that would

be admissible at trial because "the affidavits [submitted in residential foreclosure cases are]

largely derivative because [they are] drawn from a business's records, and not from the affiant's

personal observation of events").

Regardless of the admissibility of any business records regarding Lathrop's alleged

default and the amount due on the note, no documents were cited to for these propositions in

either FNMA's statement of material facts or Hampton's affidavit. Paragraph Seven ofFNMA's

Statement of Material Facts asserts that the defendant is in default and cites to Paragraph Five of

3 the Hampton affidavit? The Hampton affidavit mirrors the assertion contained in the Statement

of Material Facts but does not cite to any records. This is insufficient to support the assertion of

default. See Murphy, 2011 ME 59,~ 9, 19 A.3d 815. Likewise, Paragraph Nine of FNMA's

Statement of Material Facts cites to Paragraph Eight of the Hampton affidavit to support the

amount owed on the note. However, Paragraph Eight of the Hampton affidavit contains no

citation to any document or record to support the amount claimed. See id. Copies of some

financial records were submitted with the Motion for Summary Judgment, but they are not cited

to and therefore are not part of the summary judgment record. See M.R. Civ. P. 56.

In addition, FNMA's Statement of Material Facts does not contain a statement regarding

the Defendant's military status, which is required because the Defendant has not appeared in the

matter. 3 See Lubar v. Connelly, 2014 ME 17, ~ 37, 86 A.3d 642; HSBC Bank USA, N.A. v.

Gabay, 2011 ME 101, ~ 22, 28 A. 3d 1158 ("Facts not set forth in the statement of material facts

are not in the summary judgment record even if the fact in question can be gleaned from

affidavits or other documents attached to, and even referred to in portions of, a statement of.

material fact."); see also Higgins, 2009 ME 136, ~ 11, 985 A.2d 508.

Also, FNMA' s assertion of superior priority is does not contain a proper record citation.

See M.R. Civ. P. 56; (Pl. SMF ~ 16.) FNMA cites to a copy of the mortgage to establish its

priority but does includ~ any citation indicating that it at any time searched the registry of deeds

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Related

Chase Home Finance LLC v. Higgins
2009 ME 136 (Supreme Judicial Court of Maine, 2009)
DEUTSCHE BANK NAT. TRUST CO. v. Raggiani
2009 ME 120 (Supreme Judicial Court of Maine, 2009)
Beneficial Maine Inc. v. Carter
2011 ME 77 (Supreme Judicial Court of Maine, 2011)
HSBC Bank USA, N.A. v. Gabay
2011 ME 101 (Supreme Judicial Court of Maine, 2011)
HSBC Mortgage Services, Inc. v. Murphy
2011 ME 59 (Supreme Judicial Court of Maine, 2011)
Lewis Lubar, Trustee of the Clover Trust v. Frederick W. Connelly
2014 ME 17 (Supreme Judicial Court of Maine, 2014)

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