REQUEST FOR ADMISSION - DEMAND FOR DISCHARGE OF MORTGAGE (Regions Bank)

17 USC § 107 Limitations on Exclusive Rights – FAIR USE Page 1 of 7
REQUESTS FOR ADMISSION;
SETTLEMENT DEMAND
And
DEMAND FOR DISCHARGE OF MORTGAGE
18 U.S. Code § 1962. Prohibited activities
(a) It shall be unlawful for any person who has received any income derived, directly or indirectly,
from a pattern of racketeering activity or through collection of an unlawful debt in which such
person has participated as a principal within the meaning of section 2, title 18, United States Code,
to use or invest, directly or indirectly, any part of such income, or the proceeds of such income, in
acquisition of any interest in, or the establishment or operation of, any enterprise which is engaged
in, or the activities of which affect, interstate or foreign commerce. . .

(b) It shall be unlawful for any person through a pattern of racketeering activity or through
collection of an unlawful debt to acquire or maintain, directly or indirectly, any interest in or control
of any enterprise which is engaged in, or the activities of which affect, interstate or foreign
commerce.
(c) It shall be unlawful for any person employed by or associated with any enterprise engaged in,
or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly
or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity
or collection of unlawful debt.
UNDERSTANDING THE CONFLICTS OF INTEREST
PROHIBITING NATIVES/INDIANS/MOORISH NATIONALS…
JUDICIAL/LAWFUL REMEDIES THROUGH THE
UNITED STATES OF AMERICA’S DESPOTISM “CORPORATION” EMPIRE’S
PRIVATELY HELD COMPANIES/COURTS
FACTS ABOUT BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ:
1. Baker Donelson Bearman Caldwell & Berkowitz (“Baker Donelson”) is a PRIVATELY held company.
2. Baker Donelson IS legal counsel for the United States of America (i.e. Federal and State Agencies)
- i.e. which include the Federal Bureau of Investigation, Central Intelligence Agency…

3. Baker Donelson IS legal Counsel for the United States Executive Branch, Legislative Branch and
Judicial Branch
As of 04/09/20: https://www.slideshare.net/VogelDenise/bd-oilfield-patents
https://www.slideshare.net/VogelDenise/baker-donelson-ties-to-govt-officals-whitehouse-14530304
4. Baker Donelson CONTROLS and RUNS the United States Judicial System - i.e. placing their attorney
James C. Duff in the position of Director of the Administrative Office of the United States Courts

As of 04/09/20: https://docs.house.gov/meetings/AP/AP23/20170517/105950/HHRG-115-AP23-Bio-DuffJ-20170517.pdf
https://drive.google.com/open?id=11WvoSqj1BMPT4A_PdVNpI9UimddV3WAG
https://login.filesanywhere.com/fs/v.aspx?v=8c6a68885e647576ae6d
5. Baker Donelson CONTROLS and RUN the United States Financial System and is legal counsel for
the United States Department of Treasury . . . United States Federal Reserve – i.e. PRIVATELY held
companies.

According to information provided to the Utica International Embassy, Regions Bank and the Internal
Revenue Service was served with a:
SETTLEMENT DEMAND
And
FEBRUARY 2020
UNDERSTAND THAT THE UNITED STATES OF AMERICA/UNITED STATES’ OFFICIALS, THEIR LEGAL
COUNSEL BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ and CO-CONSPIRATORS (as
Financial Institutions…) CAN BE HELD LIABLE FOR HOMES/HOUSES, PROPERTY LOST THROUGH
FORECLOSURE SCAMS as well as the CORONAVIRUS HOAX CREATED FOR PURPOSES OF
ENSLAVEMENT, FRAUD, THEFT, HARDSHIP, etc. UNDER THEIR RACKETEERING EMPIRE(S)

FAILURE TO ACT:
There ARE LAWFUL “INTERNATIONAL” Options available to Nationals/Indians/Moorish
Nationals… that have lost their Home(s), Property, etc. as a direct result of FORECLOSURE Scams.
There are people who say, “They are not going to do anything because the System/Matrix
is CORRUPT and against them!” Keep in mind, that regardless what one may think, it is VERY
IMPORTANT to OBJECT to such Criminal Acts and War Crimes being carried out by the United
States of America’s DESPOTISM “Corporation” Empire’s Nazis/Zionists. Do so in WRITING and
through the applicable LAWFUL process so that one will have EVIDENCE of their good-faith efforts
to resolve the matter(s) in an amicable manner. Should Companies and their Officers, Employees,
Representatives and Legal Counsel, etc. FAIL TO ACT, please do NOT fall for their TRAPS to get
you before a FRAUDULENT Judicial System that is STACKED and NOT even lawful…
Attached is a FORM drafted from a similar document regarding a matter that was brought to the Utica
International Embassy’s (“UIE”) Interim Prime Minister Vogel Denise Newsome’s attention and our assistance sought because
the individual(s) was distraught and very upset, emotional, etc. upon learning of being victimized. In the following document,
we are using Regions Bank d/b/a Regions Mortgage and sharing the steps and/or procedures being used by a Moorish
National/Moorish-American. It is IMPORTANT TO NOTE:
(A) LACK OF JURISDICTION:
The United States Courts are “PRIVATELY” held companies and do NOT have JURISDICTION to hear matters involving
Natives/Indians/Moorish Nationals… and NOT Court(s) of Law but merely “COMPANIES!”
(B) From feedback provided to the UIE, it appears that Regions is attempting to FORCE a Moorish-American to bring a
Lawsuit through their FRAUDULENT Judicial System – i.e. one of their Courts (which is a PRIVATELY held company).
Because the United States is NOT a Government and do NOT have a Judicial System – but merely PRIVATELY held
companies deceptively projecting to be Courts of Law (when they are NOT).
(C) Because the United States of America/United States does NOT have a LAWFUL Judicial System and this Moorish-
American seeks relief through Moorish Laws, etc., such matters are NOT within the Jurisdiction of the allege United
States Courts (PRIVATELY held companies). Therefore, this person may want to take this matter before an
“INTERNATIONAL” Tribunal should Regions Bank and its Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz
insist on CONTINUING to subject this individual to their RACKETEERING Empire’s “FORECLOSURE SCAMS!”
(D) Natives/Indians/Moorish Nationals… should NOT subject themselves to the JURISDICTION of the
FARCE/FRAUDULENT United States “CORPORATION” Empire’s “PRIVATELY” held companies masquerading as Courts
of Law (when they are NOT)!
BOTTOM LINE: The United States FRAUDULENT Judicial System WILL NOT recognize MOORISH Nationals NOR Moorish Laws;
therefore, there is a CONFLICT, etc. and, therefore, relief may want to be sought through an “INTERNATIONAL”
Tribunal for consideration.
Moorish Nationals/Moorish-Americans are seen as SLAVES and subjected to the United States of America’s
Despotism CORPORATION Empire’s “BLACK CODES/SLAVE CODES” – which are UNLAWFUL and in ERROR, etc.
RESEARCH RESULTS: The UIE’S RESEARCH did reveal that Regions Bank is represented by Baker Donelson Bearman Caldwell
& Berkowitz. Supportive documents are being provided following the Form.

LOGO NAME
Address Information
Contact Information
LOGO
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 1 of 43
CERTIFIED MAIL RETURN RECEIPT NO. _______
SETTLEMENT DEMAND
And
RE: LOAN/ACCOUNT # _______
Purchaser(s)/Victim(s) _______
Date of Fraud 02/14/2015
ATTENTION: John M. Turner, Jr. – President/CEO
Regions Bank
c/o Office Of The Corporate Secretary
1900 Fifth Avenue North - Birmingham, Alabama 35203
Dear John M. Turner, Jr.:
I, _______ (hereinafter, “_______” a/k/a _______ [“_______”]) come to you in Love, Truth, Peace,
Freedom and Justice! As you know, beginning on or about February 14, 2015, Contracts/Instruments were
executed in regards to the above referenced LOAN/ACCOUNT entitled:
i) CONTRACT FOR THE SALE AND PURCHASE OF REAL ESTATE (02/14/15)
ii) Note (02/19/15)
iii) Warranty Deed (02/19/15)
iv) COMPLIANCE AND TAX PRORATION AGREEMENT (02/19/15)
v) DECLARATION OF ACCEPTANCE (02/19/15)
vi) American Land Title Association Settlement Statement (02/19/15)
Through this instant Requests For Admission; Settlement Demand and Demand For Discharge Of Mortgage
(“RFA/SD/DFDOM”), _______ in good faith is seeking responses and the relief set forth below under
“DAMAGES/RELIEF SOUGHT” for the role(s) Regions Bank d/b/a Regions Mortgage1
has engaged in under
the Mortgage Scam leveled against him. In support thereof, _______ states the following:
1
Regions Bank d/b/a Regions Mortgage when mentioned includes its Officers, Officials, Representatives, Employees, Agents and/or
Legal Counsel, etc.

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I. NOTIFICATION REGARDING ANSWERING/RESPONDING TO
REQUESTS FOR ADMISSION
Regions Bank d/b/a Regions Mortgage - (a/k/a hereinafter “Regions”) is hereby NOTIFIED that this
Requests for Admission is submitted for purposes of assessing and mitigating costs and further injury/harm
to _______ (“_______” and/or also known as “_______” [“_______”]). The Response(s) to the Requests for
Admission shall comply with the applicable Statute(s) and/or applicable laws governing said matters hereby
served upon Regions and shall:
1. State in short and plain terms Regions’ defense(s) to each claim asserted and shall
admit or deny averments upon which it relies;
2. If Regions is without knowledge or information sufficient to form a belief as to the
truth of an averment, Regions shall so state and this has the effect of denial. However, said
denials shall fairly meet the substance of the averments denied;
3. If Regions intend in good faith to deny only a part of a qualification of an
averment, then Regions shall specify so much of it as is true and material and shall deny only the
remainder; and
4. Be subject to the provision of the applicable Rules/Statutes and/or Laws governing
said matters. Should Regions willfully violate Rules/Statutes/Laws shall be subject to possible
disciplinary action permissible by law(s). Regions’ autograph of instrument(s) constitutes a
certification of the following:
(a) That Regions has conducted a reasonable inquiry;
(b) That Regions is satisfied that the paper/document/instrument is well
grounded in fact;
(c) That the document/pleading/instrument has a basis in existing law or that
Regions has a good faith argument to amend or reverse existing law; and
(d) That the pleading/document/instrument is not interposed for any improper
purpose, such as harassment, threats, intimidation, coercion, extortion,
blackmail, furtherance of conspiracy(s), delay or needless increase, etc. of
_______’s costs of litigation and/or to further burden him and/or taxpayers
with costs of litigation.
… If the document/pleading/instrument is signed in violation of the Statutes/Rules/Laws
governing said matters, appropriate sanctions/relief shall be sought to be imposed in the
applicable INTERNATIONAL Tribunal(s) with Jurisdiction [since there is evidence to support that
the United States of America’s Judicial System and/or Government is a FRAUD!]; moreover, is not
a Government but merely a “PRIVATELY held COMPANY!”

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Therefore, may require that _______ seek the applicable lawful recourse for recovery of
injuries/harm in an amount of reasonable relief and expenses caused by theses WAR Crimes and other
Criminal Acts leveled against him; which include reasonable attorney’s/legal fees and costs.

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Regions is hereby further NOTIFIED that:
5. That Regions is to familiarize and/or become acquainted with the
Statutes/Rules/Codes, etc. governing responsive instruments. Answers such as “failure to state
a claim,” “lack of subject matter jurisdiction,” provided for purposes of misrepresentation, delay
of proceedings, obstruction of justice, etc. will be subject to the provisions of applicable
Statutes/Rules/Codes.

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6. If Regions’ answer(s) is not sufficiently definite in nature to give reasonable notice
of the allegations/claims in this “RFA/SD/DFDOM” which (if necessary) is sought to be placed in
issue should Judicial process become necessary, Regions’ averments may be treated as admitted
(i.e. a corporate party’s denial of “each and every allegation” did not give “plain notice.”) - - For
reference purposes see: Wright & Miller Federal Practice and Procedure Civil 3d § 1261.

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7. A denial of knowledge or information requires that Regions only lack first-hand
knowledge of the necessary facts involved, but also that Regions lack information upon which it
reasonably could form a belief concerning the truth of the allegations/claims set forth in this
“RFA/SD/DFDOM.” - - For reference purposes see: Wright & Miller Federal Practice and Procedure
Civil 3d § 1262.
8. Normally, Regions may NOT assert lack of knowledge or information if the
necessary facts or data involved are within Regions’ knowledge or easily brought within
Regions’ knowledge [i.e. An Answer denying information as to the truth or falsity of a matter
necessarily within the knowledge of the party’s managing officers is a sham, and will be treated
as an admission of allegation(s)/claims set forth in “RFA/SD/DFDOM”]. The United States of
America’s (“USA”) Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz will be included
as a Party in this action in that said Law Firm retains knowledge/information and
documents/instruments regarding the USA’s Nazis/Zionists hidden agenda of Enslavement under
such Codes as “Black Codes,” Scams as “STRAWMAN,” and Supreme Court of the United States’
decisions in “Dred Scott vs. Sandford” that is secretly/deceptively being implemented Globally
under the guise of Adolf Hitler’s “NEW” World Order Agenda in efforts to make the WHITE Race
Supreme over “ALL” other Races/Religions. - - For reference purposes see: Wright & Miller
Federal Practice and Procedure Civil 3d § 1262.
9. An averment, that Regions is without knowledge or information sufficient to form
a belief as to matters that are common knowledge or of which Regions can become inform with
the slightest effort, will be treated as patently false and the effect and purpose will be taken as
such to merely delay justice. - - For reference purposes see: Reed v. Turner, 2 F.R.D. 12; and
Squire v. Levan, 32 F. Supp. 437.
10. If the Answers/Responses to the “Requests For Admission” are not in compliance
with the Statutes/Rules/Laws governing said matters, the appropriate actions will be sought
before the applicable INTERNATIONAL Tribunal(s) – i.e. Sanctions against Regions [if applicable],
restitution/reparation as well as costs of legal services and fees to defend sham/frivolous matters
before the applicable Tribunal against what appears to be merely “PRIVATELY HELD Companies”
doing business under a defunct Government which is a “privately held company” alleging to be
Court/Government Entity – i.e. when it is NOT a Court and/or Government. Moreover, said
Company(s) and its Employees are impersonating Government Agencies, Officers, etc. and are
engaging in WAR Crimes and other Criminal acts of and against _______ - - which he will
strongly/fervently OBJECT to being unjustly subjected to as implied through this instant
“RFA/SD/DFDOM” as well as his “NOTICE TO SETTLE ACCOUNT” dated on or about August 23,
2018.

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11. NOTICE IS HEREBY GIVEN: _______ does NOT wish to contract with the
“PRIVATELY HELD Company” – Regions Bank d/b/a Regions Mortgage nor its subsidiaries that are
also “privately held” companies – and, in good faith, demand the Relief set forth herein for the
injuries/harm sustained from such fraudulent and criminal acts, etc.
42 U.S. Code § 1981. Equal Rights Under The Law
(a) Statement of equal rights
All persons within the jurisdiction of the United States shall have the same right in every
State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the
full and equal benefit of all laws and proceedings for the security of persons and property as is
enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes,
licenses, and exactions of every kind, and to no other.
(b) “Make and enforce contracts” defined
For purposes of this section, the term “make and enforce contracts” includes the
making, performance, modification, and termination of contracts, and the enjoyment of all
benefits, privileges, terms, and conditions of the contractual relationship.
(c) Protection against impairment
The rights protected by this section are protected against impairment by
nongovernmental discrimination and impairment under color of State law.- - - As of 02/04/20
Cut and Pasted from: https://www.law.cornell.edu/uscode/text/42/1981

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RELEVANT FACTS TO UNDERSTAND RELIEF SOUGHT:
TACIT AGREEMENT - Occurs when two or more persons pursue by their acts
the same object by the same means. One person performing one part and the
other another part, so that upon completion they have obtained the object
pursued. Regardless whether each person knew of the details or what part
each was to perform, the end results being they obtained the object pursued.
Agreement is implied or inferred from actions or statements. - - - OBJECT
PURSUED: The CREATION Of An Unlawful Foreclosure Against _______ should
he awake and realize the Mortgage/Foreclosure Fraudulent Scheme that has
been perpetrated against him as addressed herein.
This is a matter in which it appears that Regions in fulfilling role in “BAITING the HOOK” with the selling
of a house that _______ was lured in to with such fraudulent and deceptive scams without knowledge that

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he was being pulled into FORECLOSURE Scams that are specifically perpetrated against what are known as
People-of-Color – i.e. many of such victims who are actually lawfully and rightfully entitled to the House(s)
and Lands/Territories for which they seek through their ancestry/heritage and are being duped/victimized
through such Foreclosure Scams as this! To better explain such WAR Crimes and/or criminal acts being
carried out, _______ set forth the following facts and hereby demand Answer(s) and Response(s) to the
following:
II. REQUESTS FOR ADMISSION
1. The USA no longer has a Court of Law and are operating under a “FICTION” known as Color
of Law.
□Admit □Deny
RESPONSE:
2. The USA has gone about creating a Uniform Commercial Code (“UCC”) System of Law for
fraudulent and deceptive purposes that is designed to deal in “COMMERCE” – i.e.
Business/Corporation matters. This UCC System was designed by Lawyers.
□Admit □Deny
RESPONSE:
3. With the UCC System comes “CONTRACT” Law! All transactions are done under contract
and not under Law!
□Admit □Deny
RESPONSE:
4. Regions Bank and Regions Mortgage (according to research) each are a privately held
company in ________, Florida.
□Admit □Deny
RESPONSE:

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5. _______ in good faith seek to resolve matters addressed in this instant “RFA/SD/DFDOM” in
that:
In 2007, the United Nations passed the Declaration on the Rights of
Indigenous Peoples, to help eliminate human rights violations against
them. It creates a framework for laws to make sure that issues are
addressed by working directly with Indigenous communities.
There are 46 Articles, or rules, in the Declaration, including:
 Indigenous peoples are free and equal to all others and
have the right to be free from any kind of
discrimination, including discrimination based on their
Indigenous origin or identity (Article Two).
 Indigenous people have the right to live in freedom,
peace and security.
 They must be free from genocide and other acts of
violence including the removal of their children by
force (Article Seven).
 Indigenous peoples have the right to practice and
revitalise their cultural traditions and customs (Article
Eleven).
 Indigenous peoples shall not be removed from their
land by force. Where they agree, they should be
provided compensation, and, where possible, have the
possibility to return (Article 10).
 Indigenous peoples must not be discriminated against
in matters connected with employment (Article 17).
 Governments shall consult properly with Indigenous
peoples before adopting laws and policies that may
affect them. They must use the principles of free, prior
and informed consent – which means giving
Indigenous peoples all the facts needed to make
decisions (Article 19).
 Indigenous peoples have the right to own, use and
control their lands, waters and other resources.
Governments shall recognise and protect these lands,
waters and resources (Article 26).
This Declaration is unique in that it was the first UN document created for
the people, by the people: Indigenous People from all over the world
helped to develop it, and it took more than two decades of discussions.
As of 02/04/20: https://www.amnesty.org.au/how-it-works/what-are-
indigenous-rights/
in which they (if necessary) will seek enforcement as well as Investigations and Prosecution
under the laws against those who are perpetrating such Foreclosure Scams under which they
have been robbed and fraudulently/deceptively deprived of protected rights, privileges and
immunities, etc. that are prohibited under National as well as International Laws resulting
in War Crimes and other Criminal acts that are depriving them of their Home as well as
Land/Property(s), etc.

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□Admit □Deny
RESPONSE:
6. _______ is an Indigenous Person; however, all the facts needed to assist him in making an
informed decision regarding the above referenced Loan # _______ (at the time of enaction,
etc.) were not given and/or made known to him – i.e. was withheld by Regions.
□Admit □Deny
RESPONSE:
7. _______ (being an Indigenous person) has the right to own, use and control the
lands/territories that has been purchased under Loan # _______ for Land/Territories
located and/or associated with 325 Sunny Lane– Bozeman, Florida 39556.
□Admit □Deny
RESPONSE:
8. _______’s Land/Territories associated with 325 Sunny Lane– Bozeman, Florida 39556, is
protected under the applicable Treaties and Laws governing said matters due to his
“protected” status as an Indigenous person.
□Admit □Deny
RESPONSE:
9. The Court/Justice and Police Systems have been designed to commercialize and securitize
Human Beings and/or those of Flesh and Blood without their knowledge of such War Crimes
– i.e. to be treated and/or sold on the Market as though they are Slaves – when they are
not! Systems that are privately held companies that have been categorized under the guise
of Police Protection, Local Government, Sheriff, etc. for fraudulent and deceptive purposes
to mislead and/or misrepresent to Purchaser(s)/Victim(s) - as _______ - that they are Law
Enforcement when they are not and are merely working in the interest of privately owned
corporations/companies! Thus, such companies’, etc. are only there to enforce the
interests of their employers (private company/corporation)!
□Admit □Deny
RESPONSE:

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10. CESTUI QUE VIE TRUST: This is a matter in which England’s Monarchy is alleged to have
asserted that “all living souls” are to be turned into “fictions” and are traded as “human
chattel” on stock markets making profit for the “Parent Corporation” and its odious
middlemen (Bankers) – i.e. as Regions.
As of 02/02/20: https://www.theguardian.com/politics/video/2019/jul/04/ann-
widdecombe-likens-brexit-to-slaves-turning-on-their-owners-video
https://www.youtube.com/watch?v=HUS0cBdFicI
□Admit □Deny
RESPONSE:

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11. Nation States (as Florida) are “privately” owned corporations under which they have
“bonded” slaves!
□Admit □Deny
RESPONSE:
12. United States President John F. Kennedy warned of the plot of enslavement and promised
to expose such plots. However, approximately seven (7) days of making such a statement,
he was assassinated.
□Admit □Deny
RESPONSE:
13. About August 2012, United States Vice President Joseph Biden advised of the plans of “Big
Banks” and “Wall Street” to put people “back in chains.”
As of 02/04/20: https://thebuzzcincy.com/1199398/joe-biden-says-the-darndest-things-
video/
https://thebuzzcincy.com/1199398/joe-biden-says-the-darndest-things-video/
As 02/02/20: http://217.218.67.231/Detail/2020/01/30/617481/Modern-day-Slavery-
in-the-UK
□Admit □Deny
RESPONSE:

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14. Public Trust means an express or constructive trust for either a public, religious or charitable
purpose or both, and includes a temple… church, synagogue… or other place of public religious
worship… or any other religious … endowment and a society formed either for a religious…
purpose… and registered under the Societies Registration Act, 1860. There is no central act to
govern public trusts, but various states have enacted their own separate acts according to their
conditions and administration…
A public trust is a vehicle which is set up for the specific benevolent purpose of the author to provide
for a certain purpose or object for the benefit and need of the beneficiaries who may not be
specifically defined in the trust deed, but include a wide genus of people who fall within the
parameters of the object and purpose of that trust… There is no central act to govern public trusts,
but various states have enacted their own separate acts according to their conditions and
administration. To register a public trust all one needs is a draft of trust deed stating the trustees,
the objectives of the trust, and the intended beneficiaries who are a part of the general public…
As of 12/06/19: https://www.moneycontrol.com/news/business/personal-finance/succession-
planning-understanding-public-trusts-and-their-management-2517287.html
□Admit □Deny
RESPONSE:
15. Because of the “Corporation” setup, communication has to be with the “fiction” created
known as the “STRAWMAN” where identification is made by placing characters of the
factious creation in “ALL CAPS” – i.e. as JANE DOE/JOHN DOE – which denotes “Dead”
and/or “Not Living!”
16. Corporations do not and/or cannot communicate with Human Beings.
□Admit □Deny
RESPONSE:
17. The term “STRAWMAN” was derived for “No Soul” and/or “Spiritually Dead!”
□Admit □Deny
RESPONSE:
□Admit □Deny
Understanding the process:
(a) When a mother gives birth, under their laws, she has to register the
birth of the child(ren). If the birth is not registered, she may be taken to
court.
RESPONSE:
□Admit □Deny
(b) The Birth Certificate that the Mother (who is deemed an informant)
provides is taken and (unbeknown to her), a copy is made – i.e. creating a
STRAWMAN [fiction name for the child(ren)]. In other words, the child(ren)
is turned into a TRUST.
RESPONSE:
□Admit □Deny
Than a VALUE is allocated to that TRUST – i.e. Billions of dollars are
allocated.
Creating a BOND! Becoming a Warehouse Bond for MONEY!
RESPONSE:

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□Admit □Deny
Thus, it is then TRADED through the STOCK MARKETS for Money!
Fraudulent acts that are NOT being disclosed.
RESPONSE:
□Admit □Deny
This is IDENTITY THEFT where the Child’s NAME is taken and turned into a
DEAD Entity known as the Strawman! The dead entity then begins to make
BILLIONS as it is TRADED on the Market!
RESPONSE:
□Admit □Deny
This is the ONLY way (through the Strawman) that the Corporation can
conduct business.
RESPONSE:
□Admit □Deny
When one may be required to go to Court, it is NOT going to be in the real
name because the Court (a corporation/business entity) does NOT have
your name and only engages in fictitious and/or fraudulent matters with
DEAD Entities (known as a Strawman)!
RESPONSE:

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□Admit □Deny
(c) Such Foreclosure Scams that _______ finds himself in are a direct result
of what appears to be the concerns of Thomas Jefferson (Third President of
the United States) of the People waking “up homeless…” because of
private banks (growing up around them) controlling the issuance of the
currency – first by inflation and then by deflation.
RESPONSE:
□Admit □Deny
(d) The United States Federal Reserve, belongs to England’s Royal Family!
RESPONSE:
□Admit □Deny
The United States Federal Reserve is also “a privately held company” and
is a “Headquarters” business that has been categorized under
“RECREATION” Association and established in 1936, and INCORPORATED
in District of Columbia.

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RESPONSE:
18. SIGNATURE is under the “UCC” and is used for the fiction! “Signature” is TRICKERY used
unbeknownst to Purchaser(s)/Victim(s) allowing for access to the TRUST Account to
withdraw monies! The Signature is being monetized. Monies are coming from the TRUST
Fund set up from the Birth Certificate.
Such practices are criminal and fraudulent and done without the Victim’s knowledge.
AUTOGRAPH is what a REAL Person uses!
□Admit □Deny
RESPONSE:
19. The United States of America Courts are conducting business under “COLOR OF LAW!”
□Admit □Deny
RESPONSE:
20. Color of Law is a FICTION!
System without Laws!
□Admit □Deny
RESPONSE:
21. When asking a Judge to see his/her Oath of Office, they will not be able to produce because
they are merely conducting business on behalf of the private corporation/business and
performing the duties of a Banker. The Judge is only paid if able to obtain SIGNATURE under
the Strawman which FUNDS are taken from the TRUST Account – i.e. Cestui Que Vie Trust
created from the Birth Certificate!
□Admit □Deny
RESPONSE:

Page 22 of 43
22. Going to Court in the United States regarding the above Loan # _______ will be an
automatic LOSS for _______!
□Admit □Deny
RESPONSE:
23. An Attorney’s DUTY is FIRST to the Courts and the Public; NOT to the Client – i.e. as would
be _______!
□Admit □Deny
RESPONSE:
24. Whenever, an Attorney’s DUTIES to their Client CONFLICT with those he/she owes as an
OFFICER of THE COURT in the Administration of Justice, his/her ALLEGIANCE is to the Court
under which he/she is AN OFFICER of!
□Admit □Deny
RESPONSE:
25. Attorneys/Lawyers have taken an OATH not to do anything that would harm their
PROFESSION.
□Admit □Deny
RESPONSE:
26. MORTGAGE/FORECLOSURE SCAM:
(a) “Mortgage” has been known to mean “DEATH Contract!”
□Admit □Deny
RESPONSE:
□Admit □Deny
(b) When the SIGNATURE is placed on the Mortgage Application, the
signature is taken to AUTHORIZE monies to be taken from TRUST
established from Birth Certificate STRAWMAN and the Mortgage DEBT is
PAID from monies taken FROM the Trust!
RESPONSE:
□Admit □Deny
(c) The Purchaser(s)/Victim(s) Mortgage was PAID upon signature and
monies for Mortgage was taken from the TRUST; therefore, a DISCHARGE
occurs from the Treasury BOND!
RESPONSE:
□Admit □Deny
(e) First missed payment is what scammers want so they can come after
the Purchaser(s)/Victim(s) property and/or possessions, etc.
RESPONSE:

Page 23 of 43
□Admit □Deny
(f) Turning to the Insurance Companies – which are also “privately held
companies” - to fulfill rolls in Mortgage/Foreclosure Scams.
RESPONSE:
□Admit □Deny
Thief By Night Insurance Company is NOT Licensed to do business in the
State of Florida.
RESPONSE:
□Admit □Deny
(g) Although the Purchaser(s)/Victim(s) Mortgage has been “PAID IN FULL”
from their “CESTUI QUE VIE TRUST” created from the Birth Certificate, in
such Mortgage/Foreclosure Scams, this vital/critical information is
withheld and they are led to believe that the monies are being provided
from the Lender (when it is not) – i.e. the Lender/Bank has already BEEN
PAID from monies obtained from the Trust Account!
RESPONSE:

Page 24 of 43
□Admit □Deny
Thus, the Lender/Banker through such Mortgage/Foreclosure Scams seek
to get paid AGAIN with INTEREST! Going as far as SELLING THE DEBT to a
Third-Party to now profit from such War Crimes and Criminal Acts and to
push for the completion of the Foreclosure and the THEFT/ROBBERY of the
Purchaser(s)/Victim(s) Home and Property/Land!
RESPONSE:
□Admit □Deny
(h) The Lender/Bank JUST HAVE PAPER! The “Contract” has NO Value
because the Mortgage has been PAID out of the Trust! Therefore, the
Lender/Bank now wants the PROPERTY that has already been paid for and
proceeds to engage in War Crimes and other Criminal acts – i.e. FRAUD,
ARMED ROBBERY, etc. to obtain it unlawfully and leave the
Purchaser(s)/Victim(s) “HOMELESS…”
RESPONSE:
27. On or about May 20, 2016, a “WARRANTY DEED” was executed in the use of the
“STRAWMAN” for the GRANTOR(S) and GRANTEE regarding matter associated with Loan #
_______.
RESPONSE:

Page 25 of 43
28. The SIGNATURE on the Warranty Deed, is taken to AUTHORIZE monies to be taken from
TRUST established from Birth Certificate STRAWMAN and the DEBT is PAID from monies
taken FROM the Trust to cover the expenses – i.e. Taxes, etc. associated with said
transaction(s) mentioned in the Warranty Deed.
□Admit □Deny
RESPONSE:
29. This instant “RFA/SD/DFDOM” is sufficient to serve as _______’s request for information and
NOTIFYING of ERROR(S) in the handling of the Mortgage associated with the above referenced
Loan/Account # _______.
□Admit □Deny
RESPONSE:
30. Regions will acknowledge (via “in writing”) _______’s “request for information or error
notice” – which is this instant “RFA/SD/DFDOM” within five (5) business days of receipt
unless excused under the applicable regulation…
□Admit □Deny
RESPONSE:

Page 26 of 43
31. The information contained in the following excerpt of the 2017 Form 1099-A is true and/or
correct.
□Admit □Deny
RESPONSE:
32. Regions has an Identification Number as 977256466.
□Admit □Deny
RESPONSE:
33. The information contained in the following excerpt of the 2017 Form 1099-B is true and/or
correct.

Page 27 of 43
□Admit □Deny
RESPONSE:
34. On or about May 20, 2016, Regions was “PAID IN FULL” under the original of
Contract/Application # _______.
□Admit □Deny
RESPONSE:
35. On or about February 14, 2015, a “CONTRACT FOR THE SALE AND PURCHASE OF REAL
ESTATE” was entered into between Buyer(s) _______ and Seller(s) Harold and Doris
Clogfeet.
□Admit □Deny
RESPONSE:

Page 28 of 43
36. On or about February 14, 2015, upon receipt of _______’s “SIGNATURE,” on the
“CONTRACT FOR THE SALE AND PURCHASE OF REAL ESTATE,” monies were taken from
the Trust established from his Birth Certificate AUTHORIZING the payment of the
Mortgage Debt in full for the Real Estate matter associated with Loan/Account # _______.
□Admit □Deny
RESPONSE:
37. Regions had the Real Assets obtained under Contract/Application # _______ “Bartered”
into Floating Rate Note and/or FRNs in the amount of approximately $60,500.
□Admit □Deny
RESPONSE:
38. Regions relied upon a Contract (a Promissory Note) which had my “signature” (obtained
through fraud and/or with fraudulent intent) and used said signature to conduct an “Asset
Transfer” to cover the allege Mortgage from the United States Treasury Account for ____
# xxxxxxxx____.
□Admit □Deny
RESPONSE:
39. Regions never signed on the initial Contract for deceptive purposes – i.e. role played in
Mortgage/Foreclosure Scams.
□Admit □Deny
RESPONSE:
40. Regions never loaned _______ any money.
□Admit □Deny
RESPONSE:
41. Upon receipt of the “Signature” of _______, Regions requested that Assets from my
United States Treasury Account – ____ #xxxxxxx____ – be transferred to Regions.
□Admit □Deny
RESPONSE:

Page 29 of 43
42. The Assets associated with United States Treasury Account - ____ # xxxxxxx____ – that
was withdrawn by Regions can be traced through the Federal Reserve Bank Account with
_______’s name and Account Number and Internal Revenue Service (“IRS”).
□Admit □Deny
RESPONSE:
43. The $55,000.00 in assets that Regions withdraw for Loan/Account # _______ was
processed through the Federal Reserve and Banking Systems to convert the Assets
withdrawn into FRNs (i.e. possibly tenfold) of which Regions received part of it and paid
the Seller(s) – Harold L. Clogfeet, Sr. and Doris M. Clogfeet - of the property.
□Admit □Deny
RESPONSE:
44. Regions is to inform/notify Sellers – Harold L. Clogfeet, Sr. and Doris M. Clogfeet - of the
“Inflationary Tax” that was withheld them and their United States Treasury Account(s) and
other fraudulent practices of Regions in the handling of the Mortgage – i.e. referenced
under Loan # _______.
□Admit □Deny
RESPONSE:
45. Under Title 12 of the United States Code, Regions is prohibited from lending their own
money from their own assets or from their Depositors.
As of 02/02/20: 12 U.S. Code Title 12— BANKS AND BANKING
https://www.law.cornell.edu/uscode/text/12

Page 30 of 43
□Admit □Deny
RESPONSE:
46. The National Bank Act of 1864 is still in effect and enforceable.
□Admit □Deny
RESPONSE:
47. Regions cannot LOAN Depositors’ money out; but can leverage/monetize an asset.
Therefore, there would not have been a need for Regions to execute the FIRST Contract
with _______.
□Admit □Deny
RESPONSE:
48. In the signing of Contract # _______, _______ was the Creditor and authorized Regions
(the Borrower) to withdraw $55,000.00 from his United States Treasury Account.
□Admit □Deny
RESPONSE:
49. In the handling of Loan/Account # _______, Regions was ONLY to act in a
Trustee/Fiduciary capacity.
□Admit □Deny
RESPONSE:
50. Regions can be held liable for injuries/harm that _______ suffers from as a direct and
proximate result of criminal acts brought to Regions’ attention.
□Admit □Deny
RESPONSE:
51. The United States’ Federal Deposit Insurance Corporation (“FDIC”) is a “privately held
company” in Washington, DC and is NOT a Government Agency NOR affiliated with a
Government Agency.
□Admit □Deny
RESPONSE:

Page 31 of 43
52. On or about August 30, 2018, Regions used the United States Postal Service to mail
correspondence via “CERTIFIED MAIL” to advise receipt of my payment on “Loan Number
_______” although said payment was rejected!
□Admit □Deny
RESPONSE:
53. The Checks/Instruments sent on August 23, 2018, to settle the Mortgage Debt alleged by
Regions under Loan # _______ was in compliance with the “NOTE” executed on May 20,
2016.
□Admit □Deny
RESPONSE:

Page 32 of 43
correspondence via “CERTIFIED MAIL” which states in part:
“Regions specifically disputes any claims, allegations or assertions
contained or referenced in your correspondence.”
Region going on to state,
“Neither anything contained in this letter nor any action or inaction by
Regions will be construed as any agreement, consent, assent,
authorization or admission by Regions whatsoever, nor bar or estop
Regions from taking any position or action whatsoever, nor constitute an
appointment of any person or entity as Regions’ agent or attorney-in-fact
for any purpose whatsoever.”
□Admit □Deny
RESPONSE:
correspondence via “CERTIFIED MAIL” which states in part:
“You should continue to pay your loan in accordance with its terms.”
□Admit □Deny
RESPONSE:

Page 33 of 43
56. Regions submitted its August 30, 2018 “CERTIFIED MAIL” Letter with knowledge that
Loan/Account # _______ has been “PAID IN FULL.”
□Admit □Deny
RESPONSE:
57. Regions submitted its August 30, 2018 “CERTIFIED MAIL” Letter with knowledge regarding
Loan/Account # _______ for purposes of EXTORTION, BLACKMAIL, etc. of monies from
_______ on an alleged Mortgage debt that has been “PAID IN FULL” with INTERESTS!
□Admit □Deny
RESPONSE:
58. Regions August 30, 2018 “CERTIFIED MAIL” Letter with knowledge regarding
_______ on an alleged Mortgage debt that has been “PAID IN FULL” with INTERESTS may
constitute “Using Mail To Defraud” pursuant to 18 USC §§§ 63, 876, 880 and other
Statutes/Laws governing said matters.
□Admit □Deny
RESPONSE:
constitute “Blackmail” pursuant to 18 USC § 873 and other Statutes/Laws governing said
matters.
□Admit □Deny
RESPONSE:
constitute use of “Interstate Communication” pursuant to 18 USC § 875 and other
Statutes/Laws governing said matters.
□Admit □Deny
RESPONSE:
61. On or about August 30, 2018, Regions used Federal means – United States Postal Service
– and deposited mail containing information constituting criminal acts for purposes of
EXTORTION and BLACKMAIL, etc. of monies from _______ of a Mortgage debt of
Loan/Account # _______ with KNOWLEDGE no said debt is owing.
□Admit □Deny
RESPONSE:
62. Regions continues to use the United States Postal Service’s mailing system to submit
EXTORTION and BLACKMAIL demands, etc. for a Mortgage debt regarding Loan/Account
# _______ with knowledge said debt has been paid in full.

Page 34 of 43
□Admit □Deny
RESPONSE:
63. _______ is entitled to “Release of Deed of Trust” from Regions and/or executed by
Regions in regards to Loan/Account # _______.
□Admit □Deny
RESPONSE:
64. _______ is entitled to “Satisfaction of Mortgage” from Regions and/or executed by
Regions in regards to Loan/Account # _______.
□Admit □Deny
RESPONSE:

Page 35 of 43
65. _______ has a right to defend against the fraudulent acts and/or practices of Regions
regarding the Mortgage Scam(s) leveled against him regarding Loan/Account # _______.
□Admit □Deny
RESPONSE:
66. Regions records reflect _______’s Race as being “Black” and/or “African-American.”
□Admit □Deny
RESPONSE:
67. Regions is presently servicing _______’s Loan/Account # _______ under the guise of what
is known as “BLACK CODES.”
□Admit □Deny
RESPONSE:
68. The State of Florida – a privately held company - still operates under “BLACK CODES” f/k/a
“SLAVE CODES.”
□Admit □Deny
RESPONSE:
69. It is a matter of “PUBLIC” Record that _______ is a Member of a “PROTECTED” Group – i.e.
Indigenous/Aboriginal People. Moreover, Laws that protect and prohibit Members from
such Mortgage/Foreclosure Scams under which Regions is subjecting _______ to. To which
– through this instant “RFA/SD/DFDOM” – _______ objects.
□Admit □Deny
RESPONSE:

Page 36 of 43
70. On or about August 23, 2018, _______ provided Regions with “NOTICE TO SETTLE
ACCOUNT” and payment in the amount of $55,000.00; which (although rejected) Checks
tendered were NOT returned. This payment information was made in good faith to rebut
and resolve matters regarding the allege Mortgage Debt Regions is alleging through
Loan/Account # _______.
□Admit □Deny
RESPONSE:
71. _______ is EXEMPT from the Mortgage Debt Regions is asserting to be owed regarding
Loan/Account #_______.
□Admit □Deny
RESPONSE:

Page 37 of 43
72. _______ is of Choctaw descent. Thus, protected and entitled to the exemption(s) afforded
him as a Member of said “protected” group.
□Admit □Deny
RESPONSE:
73. _______ has also elected to claim Nationality as a Moorish-American.
□Admit □Deny
RESPONSE:
74. The State of Florida is NOT a Government and is “a PRIVATELY held Company.”
□Admit □Deny
RESPONSE:
75. The United States of America is NOT a Government; however, is also “a PRIVATELY held
Company.”

Page 38 of 43
□Admit □Deny
RESPONSE:
76. Loan/Account # _______ is a Mortgage Scam being carried out by Regions against _______
in hopes that he will DEFAULT on this frivolous debt so that Regions can execute a frivolous
FORECLOSURE Scam to unlawfully seize his property.
□Admit □Deny
RESPONSE:
77. Under the United States Constitution, _______ is NOT considered a Citizen of the United
States of America/United States.
□Admit □Deny
RESPONSE:
78. The United States is merely “a PRIVATELY held Company.” Therefore, _______ CANNOT
be a Citizen of a Company/Corporation!
□Admit □Deny
RESPONSE:
79. In the Supreme Court of the United States Decision in Dred Scott v. Sandford, the High Court
deemed those labeled Black: (a) as being Slaves, (b) not Citizens, (c) are not included under
the Constitution, and, therefore, the rights and privileges it confers upon American Citizens
could not apply to them.
Dred Scott v. Sandford, 60 U.S. (19 How.) 393 (1857), was a
landmark decision of the U.S. Supreme Court in which the Court
held that the Constitution of the United States was not meant to
include American citizenship for black people, regardless of
whether they were enslaved or free, and therefore the rights and
privileges it confers upon American citizens could not apply to
them. - - As of 02/05/20:
https://en.wikipedia.org/wiki/Dred_Scott_v._Sandford
□Admit □Deny
RESPONSE:

Page 39 of 43
80. The United States House of Representatives is “a PRIVATELY held Company.”
□Admit □Deny
RESPONSE:
81. As recent as November 13, 2019, some of the United States House of Representative
Members drafted a “RESOLUTION” to address “BLACK CODES” practices.
As of 02/05/20:
https://www.congress.gov/bill/116th-congress/house-resolution/694/text?r=9&s=1
□Admit □Deny
RESPONSE:
82. Regions Mortgage Contract and/or Loan # _______ was executed with fraudulent intent to
cause _______ injury/harm. Thus, warranting the VOIDING of Contract and the allege debt
asserted under Mortgage. A debt which has already been “PAID IN FULL!” Further, relieving
_______ from the Mortgage Debt Regions may assert is still owing under Loan #_______.
□Admit □Deny
RESPONSE:

Page 40 of 43
83. Because the United States of America is NOT a Government; but merely a PRIVATELY held
Company - as is its Court. Should Regions assert it has legal remedies through a Judicial
process, JURISDICTIONAL recourse will only be permissible through an “INTERNATIONAL”
Tribunal in that _______ is NOT a Citizen of the United States of America and the United
States of America is NOT a Government – i.e. but merely a Company/Corporation – thus
LACKING Jurisdiction to handle prosecution of the claims addressed in this instant Requests
For Admission; Settlement Demand and Demand For Discharge Of Mortgage.
□Admit □Deny
RESPONSE:
84. Due to _______’s Indigenous/Aboriginal Status, he is also EXEMPT from Taxation; however,
the records of Regions will support has been TAXED and continues to be subjected to
TAXATION alleged under Loan/Account # _______.
□Admit □Deny
RESPONSE:

Page 41 of 43
III. _________________
GOOD-FAITH SETTLEMENT DEMAND
For the reasons set forth above through the Requests for Admission, in good faith, _______ hereby
seek the following relief for the injuries/harm sustained from Regions Bank d/b/a Regions Mortgage Criminal
and Fraudulent, etc. handling of Loan/Account # _______:
DAMAGES/RELIEF SOUGHT:
1) Monies in any/all Escrow Accounts associated with Loan/Account # _______.
2) Return of “ALL” Principal and Interest that has been paid regarding Loan/Account # _______.
3) WRITTEN verification of DISCHARGE of Mortgage and DISCHARGE of all COLLATERAL/LIENS
associated with Loan/Account # _______.
SETTLEMENT DEMAND
AMOUNT(S)2 DESCRIPTION3
$10,000 Pecuniary Damages - For past and future losses resulting from
fraudulent practices described in “RFA/SD/DFDOM” as well as out-of-
pocket expenses/losses reasonably expected from such criminal
violations – i.e. pain and suffering, emotional distress, etc.
$25,000 Nonpecuniary Damages - For past and future losses resulting from the
fraudulent practices complained of in this “RFA/SD/DFDOM” to
reasonably compensate for emotional pain, suffering, anxiety, loss of
enjoyment of life, humiliation, intimidation, threats, coercion,
blackmail, extortion, degradation, exploitation, and other conditions
that may reasonably be expected to arise out of such criminal practices
and conditions. These damages cannot be arithmetically calculated
because they compensate for intangible losses arising from physical
and psychological “pain and suffering” as well as from any loss of
amenities or expectations of life. ...
2 Minimum amount we believe is reasonable considering the irreparable injury/harm sustained from Criminal/Civil violations, etc.
3 Definitions are based on information obtained through research.

Page 42 of 43
"The in-exhaustive list of common factors ... that influence an award
of non-pecuniary damages includes: (a) our age; (b) nature of the
injury; (c) severity and duration of our suffering; (d) emotional
suffering; and (e) loss or detrimental impact on our life – i.e.
infringement and/or impairment on family life; impairment of physical
and mental abilities, and loss of lifestyle, etc.
$250,000 Punitive/Exemplary Damages - For malicious and reckless conduct
described in this “RFA/SD/DFDOM.” Sought to deter willful and malicious
past/present and future acts by perpetrators that were done to cause
deliberate injury/harm.
$15,000 Foreseeable Damages - Foreseeable damages are damages that both
party to the contract knew or should have been aware of at the time
when the contract was made. Apart from this one is entitled to recover
foreseeable damages, beyond the limits of your policy, for breach of a
duty to investigate, bargain for, and settle claims in good faith for the
criminal acts as described in this “RFA/SD/DFDOM.”
$30,000 Discretionary Damages - Discretionary damages are damages that are
not directly quantitative but are capable of being measured by the
enlightened conscience of an impartial juror. Generally discretionary
damages are awarded for mental anguish or pain and suffering. It is
also called as indeterminate damages as shown in this
“RFA/SD/DFDOM.”
$55,000 Liquidated Damages - Liquidated damages (also referred to as
liquidated and ascertained damages) are damages whose amount the
parties designate during the formation of a contract for the injured
party to collect as compensation upon a specific breach.
$25,000 Consequential Damages - Consequential damages, otherwise known
as special damages, are damages that can be proven to have occurred
because of the failure of one party to meet a contractual obligation.
They go beyond the contract itself and into the actions that flow from
the failure to fulfill.
$68,000 Actual Damages - Actual damages refer to the financial amount that
is paid to a victim that suffered loss that can be calculated. Actual
damages are often known as real damages or, legally, as
compensatory damages as described in this “RFA/SD/DFDOM.”
For the reasons set forth in this instant “RFA/SD/DFDOM,”
_______ hereby extends to Region 30 days from mailing of this
Instrument/Document to accept the demand(s) set forth.
Please be advised that after these 30 days, 1.5% interest is to be applied/added daily to each of the
Settlement Demand Amount(s) thereafter until a settlement may be reached. Regions will be held liable for
any/all legal fees, etc. associated with the Settlement of the Mortgage Debt associated with Loan/Account
# _______. Regions has a duty and obligation to mitigate damages (injury/harm) sustained by _______ as a
direct and proximate result of this Mortgage Scam.

Page 43 of 43
IV. _____
The below Autographer, _______ (“_______”) of 325 Sunny Lane– Bozeman, Florida 39556, pursuant
to the applicable Statutes/Laws governing said matters, request that within 30 Days from the mailing of this
“DEMAND FOR DISCHARGE OF MORTGAGE,” that Regions Bank d/b/a Regions Mortgage:
1. Execute, acknowledge, and deliver to _______ at 325 Sunny Lane– Bozeman, Florida 39556
at his Mailing Address of Post Office Box 39885 – Bozeman, Florida 39556, a Certificate of
Discharge of Mortgage – that is duly Sworn To and Notarized, etc. - that the Mortgage
dated February 14, 2015 and identified as LOAN # _______ executed by _______ (as
Mortgagor), to Regions Bank d/b/a Regions Mortgage (as Mortgagee), and recorded on
February 23, 2015, as Inst. 987621 in Book 1000, Page 0250, in the Office of the Clerk in
the Chancery Court, in the County of Oakland, in the State of Florida, has been fully paid,
satisfied in full, and hereby releases and discharges any and all right, title, interest claim
and demand at law and in equity that Regions Bank d/b/a Regions Mortgage may have to
the Mortgage (Loan # _______) and the property described therein. Furthermore, that said
“Discharge of Mortgage” shall inure to the benefit of the Owner (_______) and his heirs,
executors, legal representatives, successors and assigns.
2. Regions Bank d/b/a Regions Mortgage execute a “SATISFACTION OF MORTGAGE,” to be
recorded in the Office of the Clerk in the Chancery Court, in the County of Oakland, in the
State of Florida, acknowledging that the Mortgage associated with Loan #_______ has been
fully paid, satisfied in full, and Regions Bank d/b/a Regions Mortgage hereby releases and
discharges any and all right, title, interest claim and demand at law and in equity Regions
may have to said Mortgage Loan # _______ and the property described therein – i.e.
Recorded as Inst. 987621 in Book 1000, Page 0250 in said Chancery Court.
The below Autographer further requests Regions Bank d/b/a Regions Mortgage deliver to him at the
above-stated Mailing Address, the Mortgage, the NOTE secured by the Mortgage, and all other
documents/instruments evidencing the alleged indebtedness secured by the Mortgage under Loan #
_______.
Dated this 5th
day of March, 2020.
Autograph: _______________________________________
_______ (a/k/a _______)
Print Name: _________________________________
Phone Number: (688) 888-8888
PLEASE BE ADVISED: _______ reserves the right to amend this instant “Requests For Admission;
Settlement Demand and Demand For Discharge Of Mortgage” should it become necessary.
Respectfully submitted in Love, Truth, Peace Freedom and Justice,
Autograph: ___________________________________

UNDERSTANDING THE UNITED STATES OF AMERICA’S
RACKETEERING EMPIRE
THAT IS CONTROLLED AND RUN BY THEIR LEGAL COUNSEL
BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ
Just as Baker Donelson IS Legal Counsel for Regions Bank, our research ALSO REVEALS that Baker
Donelson is ALSO Legal Counsel for Wyndham!

Cut and Pasted As of 04/08/20:
https://www.nashvillepost.com/home/article/20403748/nashville-at-law-regions-and-hotel-chain-go-to-war
Nashville at law: Regions and hotel chain go to war
authors E. Thomas Wood
Nov 15, 2009
A $255 million alleged fraud scheme, a bank that found itself unhappily drawn into the hotel business, and a
hotelier suspicious of the bank’s motives — such are the plotline elements of a dispute that has landed in
Nashville’s U.S. District Court.

Regions Bank filed suit earlier this month against Wyndham Hotel Management Inc. over the fate of a suburban
Chicago hotel formerly owned by WexTrust Capital LLC. A federal grand jury in New York last July indicted two
top officials of Chicago-based WexTrust on charges of securities fraud, mail fraud, wire fraud and conspiracy,
claiming their enterprise was a $255 million Ponzi scheme that mainly targeted Orthodox Jews.
Regions, based in Birmingham, filed the lawsuit in Nashville because its real estate loan administration group
is located here. Exhibits to the filing show that John H. Rowland, with the Nashville office of Baker Donelson
Bearman Caldwell & Berkowitz PC, represented the bank in correspondence with Wyndham preceding the
litigation. David E. Lemke, Lea Carol Owen and Michael Harmon of Waller Lansden Dortch & Davis LLP are
representing Regions in the lawsuit.
Parsippany, N.J.-based Wyndham managed the Drake Oak Brook Hotel on behalf of WexTrust, which had
borrowed $16.7 million from Regions to buy the hotel, located west of Chicago. Earlier this year, a New York
court dealing with WexTrust’s receivership ordered that the Drake be ceded to Regions because the debt on the
property was greater than its value.
Since that point, Regions claims, it has fronted more than $500,000 to cover operational costs at the hotel. After a
few months, the lawsuit says, “precipitous declines in revenue” made it “necessary to shut down the Drake Oak
Brook Hotel.”
Regions asserts that it entered into an agreement with Wyndham under which the bank would provide further
funding to cover the process of shutting down the place. In exchange, the bank says, Wyndham agreed to stop
charging management fees and end the management agreement.
“Until October 5, 2009, Regions believed that Wyndham was proceeding to fulfill its obligations under the
shutdown agreement,” the complaint states. “Then, on that date, Wyndham suddenly advised Regions that it
considered Regions’ conduct to have violated Wyndham’s rights” under the pact.
After a series of increasingly sternly worded e-mails and letters back and forth last month, which have been filed
as exhibits, Regions took legal action, accusing Wyndham of breach of contract and unjust enrichment. The bank
asks the court to declare that its interpretation of the agreements with Wyndham is the right one, and it seeks
unspecified compensatory damages.
Wyndham’s perspective on the dispute comes through clearly in an Oct. 29 letter from Lynn A. Feldman, its
executive vice president and general counsel. Feldman stated that Wyndham had just learned of a January 2008
agreement under which the hotel’s former owner assigned its interest in the management agreement to Regions.
She wrote:
It appears that Regions chose not to disclose the Assignment to Wyndham at any point during the 22 months that
Wyndham has been managing the Drake Oak Brook Hotel. The correspondence and other communications reflect
that Regions consistently portrayed itself simply as the “lender”… without revealing that it had also become the
legal assignee of the owner’s obligations. Wyndham repeatedly asked for assistance from Regions in making
payments due to employees, utilities, repair services, other vendors, and to Wyndham itself for overdue
management fees. Despite what we now know to have been Regions’ obligations under the management
agreement and the assignment, Regions concealed those duties, and left Wyndham to struggle with the financial
burdens of operating the Wyndham Drake Oak Brook and caring for its guests.Wyndham and other vendors have
suffered substantial injury as a result of Regions’ breach of the management agreement. As our counsel explained
to you earlier this week, Wyndham itself is due more than $1.9 million….

Feldman concluded by attacking Regions’ assertions, made in “multiple letters from its Nashville counsel,” that
Wyndham’s acceptance of payments under the shutdown arrangement meant it waived the right to keep running
the hotel, leaving the bank free to sell it to a competing hotel operator.
“We emphasize that Wyndham has a continuing future right to manage this hotel, using the Wyndham name and
trademarks, and to be free of any disturbance of that right by Regions or any other entity,” Feldman wrote.
None of the parties to the case had any comment when contacted about it.

of 1
Rowland, John H.
From: Rowland, John H.
Sent: Thursday, August 06, 2009 1:37 PM
To: 'Taylor, Tanya'
Subject: Regions Funding of Drake Hotel
Tanya--
This will confirm the general terms of the agreement between Regions Bank and Wyndham with respect
to Regions further funding of The Drake Oakbrook (the "Hotel").
Regions on this date has authorized and is prepared to wire to Wyndham $180.000 to assist in the funding of the
Hotel's operations through Wyndham's proposed shut down date of September 30. 2009. In addition to this
amount, Wyndham is allowed to draw down and use for operations amounts in the Hotel's FF&E account, which
account is part of Regions collateral. This account consists of between $20,000 and $30,000. This will be the full
extent of Regions' funding through the closing date,
In exchange for providing such funding, Wydham will take steps to terminate the existing Management
Agreement and the corresponding SNDA such that on the date of the shut down the property will not be
encumbered by any claims asserted by Wyndham with respect to these agreements. Regions and Wyndham will
mutually release one another. The parties will work together over the coming weeks to document this agreement
in a formal manner.
Again, Regions appreciates the cooperation of Wyndham in this process and we especially appreciate the efforts
of your group over the last several days to reach a resolution to this difficult situation. If your understanding of the
general terms of our agreement are different than those outlined here, please let me know immediately. Thanks
again.
John
John H. Rowland
Baker, Donelson, Bearman, Caldwell & Berkowitz, PC
211 Commerce Street
Suite 1000
Nashville, TN 37201
Direct: 615.726.5544
Fax: 615.744.5544
Mobile: 615.715.6160
Email: Jrowland@bakerdon.elson.com
www.oakeroOllelso[1.com
Baker, Donelson, Bearman, Caldwell & Berkowitz
IS a full serVice, regional law firm with offices In
Alabama, Georgia, Louisiana, Mississippi, Tennessee, and
Washington, D.C
10/8/2009
Case 3:09-cv-01054 Document 2-4 Filed 11/03/09 Page 1 of 5 PageID #: 104

of 1
Rowland, John H.
Sent: Thursday, August 06,2009 1:43 PM
To: 'Taylor, Tanya'
Subject: Clarification
Tanya--
I realize it probably goes without saying, but the property being unencumbered means that Wyndham is not
charging management fees through the date of the shutdown. I just wanted to clarify that point, which we
discussed previously. Sorry for any confusion. Thanks again.
John
lohn H. Rowland
211 Commerce Street
Suite 1000
Nashville, TN 37201
Direct: 615.726.5544
Fax: 615.744.5544
Mobile: 615.715.6160
Email: irowland@bakerdonelson.com
www.bakerdonelson.com
is a full service, regional law firm with offices in
Alabama, Louisiana, Mississippi, Tennessee, and
Washington,
10/8/2009

of2
Rowland, John H.
From: Rowland, John H,
Sent: Friday. August 07, 2009 12:59 PM
To: 'Feldman, Lynn'
Subject: RE:
Lynn--
I think we're pretty much saying the same thing, There are a couple of points that might bear some further
discussion. so I need to know whether the wire needs to move today,
John
John H. Rowland
211 Commerce Street
SUite 1000
Nashville, TN 37201
Direct: 615.726.5544
Fax: 615.744.5544
Mobile: 615.715.6160
Email: jrowlanci@bakerdonelson..com
Washington, D.C.
From: Feldman, Lynn [mailto:Lynn.Feldman@wyndhamworldwide.com]
Sent: Friday, August 07, 2009 11:53 AM
To: Rowland, John H.
Cc: Taylor, Tanya
Subject:
Dear John,
We appreciate your efforts to summarize the notes of yesterday's call. Although the numbers and
dates are basically right, there are a few factual statements that were not reflected as clearly in the email
as they were in our discussions. First, we confirm that we received your August 4. 2009 notice that the
bank has begun foreclosure proceedings. We understand that the bank is willing to assist in the funding
of the hotel operations through September 30, 2009, on the condition that the hotel is closed as of that
date. In order to keep the hotel open in September, then, Wyndham has acquiesced to the September 30
shut down, and declined to agree to close the facility by the earlier deadlines the Bank had proposed
earlier. Second, with respect to our plans for the Management Agreement and the SNDA, we should be
specific about the steps Wyndham and Regions plan to take. Because the Owner's unpaid, past-due
obligations to Wyndham now exceed $500,000. Wyndham is preparing a notice of default in accordance
with the Management Agreement, ",.:hich will trigger the termination of Wyndham's obligations under
that agreement. [n exchange for the S180,000 in financing from Regions Bank for the hotel operations
through September 30. harring any unforeseen emergencies, Wyndham will fork with you on language
10/8/2009

of2
that will release the property from the encumbrances set forth in the SNDA, and will negotiate a
reasonable set of releases between Regions Bank and Wyndham. Finally, yes, Wyndham understands
that the funding agreement with Regions Bank for the hotel operations will not include funding for our
management fee, although we do expect funding for other regular fees for items such as reservation fees,
online travel agent fees etc.
With those clarifications in mind, we recognize the substantial indebtedness that Regions Bank is
can-ying on this propel1y, and appreciate your client's efforts to cooperate in reaching a resolution of this
situation, and to avoid disruption and inconvenience to the guests and employees, to the extent possible.
Best regards, Lynn
lynn A. Feldman
Executive Vice President and General Counsel
Wyndham Hotel Group
22 Sylvan Way
Parsippany, New Jersey 07054
Tele: 973-753-6461
Fax: 973-753-6760
Iynn.feldman@wyndhamworldwide.com
For every kind of traveler. For every kind of trip. www.WyndhamWorldwide.com
PLEASE NOTE THAT OUR STREET ADDRESS HAS CHANGED TO 22 SYLVAN WAY.
ALL OTHER CONTACT INFORMATION REMAINS THE SAME.
The infonnation in this electronic mail (lie-mail") message may contain infonnation that is confidential
andlor privileged, or may otherwise
be protected by work product or other legal rules. It is solely for the use of the individual(s) or the entity
(ies) originally intended.
Access to this electronic mail message by anyone else is unauthorized. IfyOll are not the intended
recipient, be advised that any unauthorized
review, disclosure, copying, distribution or use of this information, or any action taken or omitted to be
taken in reliance on it, is prohibited
and may be unlawfuL Please notify the sender immediately if you have received this electronic message
by mistake, and destroy all copies ofthe
original message.
The sender believes that this e-mail and any attachments were free of any virus, wonn, Trojan horse.
malicious code and/or other contaminants
when sent. E-mail transmissions cannot be guaranteed to be secure or en-or-tree, so this message and its
attachments could have been infected,
COITupted or made incomplete during transmission. By reading the message and opening any
attachments, the recipient accepts full responsibility
for any viruses or other defects that may arise, and for taking remedial action relating to such viruses
and other defects. Neither
Wyndham Worldwide Corporation nor any of its affiliated entities is liable for any loss or damage
arising in any way from, or for errors or
omissio11s in the contents of, this message or its attachments
10/8/2009

of3
Rowland, John H.
Sent: Friday, August 07, 2009 1:45 PM
To: 'Feldman, Lynn'
Cc: Taylor, Tanya
Subject: RE:
Lynn--
Thanks for the quick return call. I think we're on the same page.
The Bank's funding commitment is $180,000 plus the funds in the FF&E. Ijust want to be clear that the Bank
may, and in all likelihood will, reject any additional funding requests, regardless of the nature of such
requests. Clearly, the Bank supports the decision to shut down the hotel by September 30. The Bank's primary
motivation is based on what appear to be the continuing (and significant) funding requirements to maintain
operations. In reality, the Bank's decision is to cease funding. I think the natural outgrowth of that decision leads
to the decision to shut down.
Again, thanks for your continued cooperation. Regions is prepared to wire the funds. I am working hard to make
it happen today.
John
John H. Rowland
211 Commerce Street
Suite 1000
Nashville, TN 37201
Direct: 615.726.5544
Fax: 615.744.5544
Mobile: 615.715.6160
Email: jrowland@bakerdonelson.com
washington, D.C.
From: Feldman, Lynn [mailto:Lynn.Feldman@wyndhamworldwide.com]
Sent: Friday, August 07,2009 11:53 AM
To: Rowland, John H.
Cc: Taylor, Tanya
Subject:
Dear John,
We appreciate your eff0l1s to summarize the notes of yesterday's call. Although the numbers and
dates are basically right. there are a few factual statements that were not reflected as clearly in the email
as they were in our discussions. First, we confirm that we received your August 4, 2()09 notice that the
10/8/2009

ttSCHIFFHARDINLlP
Paula J. Morency
312-258-5549
pmorency@schlffhardln.com
VIA E-MAIL AND U.S. MAIL
John H. Rowland, Esq.
October 5, 2009
211 Commerce Street, Suite 1000
Nashville, TN 37201
Re: Wyndham Drake Oak Brook
Dear Mr. Rowland,
6600 SEARS TOWER
OIlC,GO, ILUNOIS 60606
t 312.258.5500
f 312.258.5600
www.schiffhardin.com
We represent Wyndham Hotel Management, Inc. ("Wyndham"), and write to express
concern regarding actions of Regions Bank (the "Bank") that appear to violate Wyndham's
rights under the January 10, 2008 Subordination and Non-Disturbance Agreement (the "Non-
Disturbance Agreement") between the Bank, Wyndham and Drake Oak Brook Holdings LLC
(the "Owner").
The Non-Disturbance Agreement between the parties has not been modified, despite
discussions between the Bank and Wyndham over the last few months regarding potential
changes to its terms. It appears to Wyndham that, in those discussions and associated
correspondence, you and/or your client made a series of representations that were either untrue
or materially misleading, in an effort to persuade Wyndham to release the rights it holds under
the Non-Disturbance Agreement. Accordingly, Wyndham is no longer willing to modify the
terms ofthat agreement.
Wyndham has managed the Wyndham Drake Oak Brook hotel diligently since January
2008, permitting the hotel to use the Wyndham Marks and to benefit from the goodwill
associated with the Wyndham name. Under the January 10, 2008 Hotel Management
Agreement, Wyndham has booked guests and events, collected revenues, paid the expenses of
the hotel, and otherwise expended substantial unreimbursed amounts on behalfofthe hotel.
Under the Non-Disturbance Agreement, the Bank committed to respect Wyndham's
rights and role under the Hotel Management Agreement, which extends by its terms for the next
25 years, including 10 years of renewal rights. The Bank agreed that, if it decided to sell or
transfer its interest to a third party, Wyndham's possession and operation of the hotel under the
CHICAGO I WASHINGTON I NEW YORK I LAKE FOREST I ATLANTA I SAN FRANCISCO I BOSTON

t_SCHIFFHARDINllP
October 5, 2009
Page 2
Hotel Management Agreement "shall remain undisturbed..." (Non-Disturbance Agreement, Pars.
5(c), 3). The Bank pledged to obtain Wyndham's consent, and then to notify Wyndham within
10 days after any termination or release of the Bank's interest. (Id., Pars. 2, 5(c». Wyndham is
entitled, of course, to withhold its consent under the circumstances set forth in Par. 10.2 of the
Hotel Management Agreement, which is incorporated into the Non-Disturbance Agreement by
reference. If Wyndham does consent, then the new transferee is required to acknowledge that
"the Management Agreement is in full force and effect and binds both Wyndham and such
transferee." (Non-Disturbance Agreement, Par. 4).
The Bank has assured Wyndham repeatedly that it has made no such transfer, and made
that representation as recently as your September 9, 2009 email. Indeed, when Crain's Chicago
Business reported that Regions Bank had sold its interest in the hotel to a company called
Crestmoor, you responded, "We haven't sold anything to anyone (unfortunately)."
Late last week, we learned that the representations from you and/or your client were
untrue. Crestmoor has now filed a lawsuit in DuPage County to foreclose upon the Wyndham
Drake Oak Brook Hotel, alleging that Crestmoor is the holder of the interest that was transferred
to it on July 27, 2009 by the Bank, through the Bank's affiliate Regions Acquisition
Management. Notwithstanding that transfer, your August 5, 2009 letter advised Wyndham that
"Regions Bank" was beginning foreclosure proceedings, and failed to notify Wyndham of the
transaction with Crestmoor, in flagrant violation of the Non-Disturbance Agreement.
Wyndham recognized, in its discussions with you and your client, that the Owner owed a
substantial amount both to the Bank and to Wyndham. In order to protect the experiences of the
guests who had booked rooms and events at the hotel, including a substantial number of
weddings, in its role as manager and agent Wyndham sought and obtained additional Bank
funding for the property, for maintenance and operations. None of that funding was for
Wyndham's past due or future management fees. In August and September, Wyndham
nevertheless considered releasing its rights under the Non-Disturbance Agreement, because the
Bank represented that there would be no further funding and that it was "shutting down the
hotel." In contemplation of that shutdown, Wyndham showed the Bank a draft letter for
termination of the Hotel Management Agreement (for defaults that the Bank had the legal right
to cure). The Bank chose not to cure, and Wyndham has not issued a termination letter to the
Owner.
It now appears that the Bank was neither planning to force a closure of the hotel nor to
cure the Owner's defaults. Instead, the Bank already had closed on an undisclosed transfer ofits
interests, to someone who, on information and belief, intends to have the hotel funded and run
under a competing brand. In violation of the Non-Disturbance Agreement, the Bank failed to

ttSCHIFFHARDfNLLP
October 5, 2009
Page 3
seek Wyndham's consent, failed to disclose the transfer, and carefully misled Wyndham when a
press report surfaced. Although both the Bank and Crestmoor are bound to comply with the
Non-Disturbance Agreement (par. 10), neither entity has provided any of the notices or
assurances required by its terms.
The circumstances that led Wyndham to consider releasing its rights under the Non-
Disturbance Agreement are materially different from the facts that the Bank concealed. In order
to avoid further violation ofWyndham's rights, Wyndham will require that the Bank and its third
party transferee: 1) submit sufficient information to Wyndham so that Wyndham can
immediately evaluate whether to exercise its right to withhold consent to the transfer; 2) if
Wyndham approves the transfer, provide Wyndham with a written instrument of attornment as
specified in Par. 4 of the Non-Disturbance Agreement; and 3) avoid any disturbance or
interference with Wyndham's possession and operation ofthe hotel.
Counsel r

BAI(E~
DONELSON
BEAIU.1AN, CiLDWELL
Be. BERKOWITZ, PC
JOH:-l H. ROWLA~D
Direct Dial: 615.726.5544
I)irect Fax: 615.744.5544
E-.1ail Address: jrowland@bakerdonelson.com
Paula J. Morency
Schiff Hardin LLP
6600 Sears Tower
Chicago, IL 60606
Dear Paula:
October 7, 2009
CO"IMERCE CF.NTER
SUfTE 1000
211 COMMERCE STREET
"ASHVILLE. TEN"ESSEE H20l
PHONE 615 726 5600
FAX, 615.726.0464
~NJJ.::-:9 AI?.QRt?~.
po. ROX 190613
'>/SlIVILLl'. TE,,:-';ESSEE 3i2t9
www bakerdonC'lson com
VIA EMAIL AND U.S. MAIL
On behalf of Regions Bank ("Regions") I am in receipt of your letter dated October 5, 2009.
apologize for the delay in responding, but I have been out of the office for the last day and a half. There
are several inaccuracies in that correspondence that I believe could have been cleared up with a simple
phone call between the paliies. In fact, Regions and Wyndham Hotel Management, Inc. ("Wyndham")
have worked together in a cooperative manner during this difficult transition period, and
particularly after the property was relinquished from the Wextrust Receivership.
First and foremost, there has not been a sale of the property. Per the agreement between
Regions and Wyndham, and as discussed and disclosed to your client (and as noted in your letter),
Regions planned to initiate foreclosure of the property, with the ultimate goal being a sale of the
property. In order to accomplish that task, which as you know under Illinois law can take several
months, Regions itselfforrned Crestmoor as a special purpose entity ("SPE") simply to hold the note and
mortgage during the pending foreclosure period, and in order to serve as a morgtagee in possession
during the period of time between the closing of the hotel and any subsequent foreclosure and/or sale.
Because Wyndham was not going to be managing the property after September 30 (Wyndham
subsequently decided to extend the closing/shutdm1J11 date to October 30), Regions had to be prepared to
oversee a closed hotel property without the benefit of a management company. Crestmoor is a wholly-
owned Regions entity formed specifically and solely for that purpose and in order to carry out the terms
of the agreement between Wyndham and Regions. From Regions perspective, it made better sense to
have an entity named Crestmoor serve as mortgagee in possession, rather than having "Regions
Bank" serve in that capacity. As you probably know, there are a number ofmechanics liens and
~.; KPf: 703127 , I
27 <.H021·()()0028 7/3lil009

October 7, 2009
Page 2
claims that have been asserted against the property. The formation of Crestmoor to prosecute the
foreclosure was simply an effort to minimize the risk to the bank (and to Wyndham, as the prior
manager of the hotel) as it moved forward under its agreement with your client, thus my statements to
Wyndham at the time the Crain's article emerged.
As Wyndham knows, Regions has been and continues to actively market the property. I will be
happy to share the status of those efforts and discuss any other matters necessary to move forward.
Again, the actions taken by Regions are in furtherance of the agreement between the parties, not in
contravention of that agreement. Regions hopes that this resolves any misunderstanding in this process.
rlook forward to discussing this matter with you at your convenience.
Sincerely,
BAKER, DONELS '-B~
CALDWE & RKO Z. P.e./- .
. /
JHR:hnr
cc: George Patton
N KPJ: 703127 v I
2791 021·0(J0028 mL'200l}

BAI(E~
DONELSON
BEA)Uv1AN, CALDWELL
&. fiFRKOWITZ. PC
JOliN fL ROWLAND,
Direct mal: 615,726.5544
J)irect Fax: 615,744.5544
E-iiail Addr"", jrowlaml(iiibak~rdllnclslm,C(lm
BAKER DO?'ELSOS CENTER
SUITE j(l<)O
HI Co~.rMERCE STREET
S,SIlVILLl'. Tf'''''f.SSEJ: H20J
PHON!': 61),7 2() 56011
FAX, 615 HO.0464
~iILI:;C. AI)DRI:'~'
P,0, 8()X 19lHil I
"NiJrI'II.LL TE;-';NFS~I'E 17119
V",'·.bak~rdltutlsuH ('{Btl
October 8, 2009
Paula 1. Morency
Schiff Hardin LLP
6600 Sears Tower
Chicago, IL 60606
Re: Wyndham Drake Oak Brook Hotel
Dear Paula:
Via E-Mail toPmorellcv@Schiffhardin.com
This is in response to your letter to me dated October 5, 2009 and our phone conversation of this
date. You have raised concems that the $16,660,500 loan (the "Loan") fr0111 Regions Bank ("Bank") to
Drake Oak Brook Holdings LLC ("Borrower") has been transferred without the consent of your client,
Wyndham Hotel Management, Inc. ("Wyndham"). You allege that such transfer is a violation of the
Subordination and Non-Disturbance Agreement (the "SNDA") by and between the Bank, Wyndham and
the Borrower dated as of January 10, 2008.
The Bank has transferred its interest in the Loan and all documents evidencing andlor securing
the Loan ("Loan Documents") to Crestmoor One, LLC, a Delaware limited liability company
("Crestmoor"). The sole member of Crestmoor is Regions Acquisition Management, LLC ("RAM").
The sole member of RAM is the Bank. Thus, the Loan and all Loan Documents remain within the
complete and unfettered control ofthe Bank.
We are unable to find any provision of the SNDA which is violated or breached by the transfer
of the Loan and Loan Documents to Crestmoor. Such transfer is not a "Post-Default Transfer" nor a
"Foreclosure Event" (as stich temlS are defined in the SNDA). Further, the Bank has not tem1inated or
released its mortgage, security deed or interest in the Hotel.
Indeed, the SNDA contemplates that a Post-Default Transfer of the Project to Bank "or its
as a resul1 of a Foreclosure Event is permitted without consent of
Wyndham (Section 2). If a transfer of the Project to an affiliate of the Bank is pennitted by the SNDA,
then why would a mere transfer of the Loan and Loan Documents to such an affiliate be of concern to
Wyndham'?

Paula H. Morency
October 8,2009
Page 2
The SNDA goes further, in Section 10, to provide that the SNDA shall be binding upon and shall
inure to the benefit of the parties and their respective successors and assigns. Section 9 contemplates
that the SNDA would inure to the benefit of a future holder of the Senior Debt. There simply is no
restriction in the SNDA on the Bank's ability to assign its interest in the Loan, even to an unaffiliated
third party.
All this being said, the Bank has appreciated Wyndham'S cooperation since the time the Hotel
was relinquished from the Receivership. Ms. Taylor, Mr. Green, and the other members of Wyndham's
corporate team have been responsive and professional under what have been difficult circumstances at
the property level.
As I explained this morning, the Bank's sole intent in the fonnation and assignment of the Loan
and Loan Documents to Crestmoor was to provide an additional layer of protection to the lender given
the actions of the owner and the dismal operational condition of the asset. Foreclosure was initiated
only after discussions with Wyndham and after providing notice of the Bank's intent to proceed in such
manner. As you may know, at Wyndham's request, the Bank provided several hundred thousand dollars
in funding to maintain operations following relinquishment of the property from the Receivership.
Regardless of the how the parties choose to proceed, the Bank is not in a position to provide any
additional funding for operations. Accordingly, I hope that we can proceed on the path agreed to
previously by our respective clients. Finally, Wyndham should understand that the Bank does not take
the position that the assignment of the Loan and Loan Documents to Crestmoor relieves the Bank from
its obligations under the tern1S of the SNDA.
If you have questions or wish to discuss further, please do not esitate to contact I e.
JHR:srs
cc: George Patton
Randal Mashburn
Kenneth P. Ezell, Jr.

Jon C. Vigano
312-258-5792
jvigano@schiffhardin.com
October 12, 2009
Baker, Donelson, Beannan, Caldwell & Berkowitz, PC
211 Commerce Street, Suite 1000
Nashville, TN 37201
Dear John,
6600 SEARS TOWER
CHICAGO, IlliNOIS 60606
t 312.258.5500
( 312.258.5600
www.schiffhardin.com
Since our telephone call last week, we have received your October 7 and October 8, 2009
letters, as well as your October 8 email. We appreciate and have reviewed the documentation
you attached regarding the incorporation and transfers to Crestmoor One, LLC. However, we
are still awaiting the other infonnation you discussed with Paula Morency and me, and remain
concerned both by our conversation and by the failure of Regions Bank to provide notice
required by the January 10, 2008 Subordination and Non-Disturbance Agreement (the "SNDA").
As noted in our October 5 letter, Paragraph 5(c) of the SNDA explicitly provides, "Bank
also agrees to notify [Wyndham] within ten (10) days after any tennination or release of Bank's
mortgage, security deed or interest in the Hotel." Regions Bank clearly transferred its mortgage
and interest in the hotel, to Regions Acquisition Management LLC ("RAM"), which then made a
transfer of those same interests to Crestmoor. The SNDA does not restrict the Par. 5(c) notice
requirement to transfers made to unaffiliated entities. Furthennore, while you have sent us the
organizational documents for Crestmoor, we asked for that infonnation because you had told us
last week that Regions Bank transferred its interests directly to Crestmoor. Now that you have
advised us of the intervening transfer to RAM, we request that you send us its organizational
documents as well, including a list and description of any members or others who have held
interests in RAM between July 1, 2009 and the present.
As you confinned in our call, there were no discussions with any Wyndham personnel
regarding either of the transfers that occurred on July 27, 2009, whether to RAM or to
Crestmoor. Indeed, the only infonnation that you or Regions Bank provided was nearly six
weeks later, when Crain's reported the transfer to Crestmoor, and you responded to Tanya Taylor
of Wyndham, "I'm not sure where this infonnation came from - not us, and it's not correct."
Frankly, we do not understand that denial, or your statement at the beginning of our call last
week that the Crestmoor entity was only "fully pulled together within the last month," (despite
CHICAGO I WASHINClDN I New YORK I LAKE FOREST I ATLANTA I SAN FRANCISCO I BOSTON

~tSCHIFFHARDINup
October 12, 2009
Page 2
what you now confirm to have been a March 2009 formation date). We also do not understand
the purported reasons why the two transfers occurred, or why Regions Bank would conceal them
from Wyndham in violation ofthe SNDA.
We ask again that you confirm, and provide all documentation regarding, any
discussions, memos, letters of intent, contracts or other dealings between Crestmoor One,
Regions Bank (or any affiliate or agent) and any entity owning or having an interest in any brand
other than Wyndham, with respect to the operation or branding of the hotel currently known as
the Wyndham Drake Oak Brook.
Given the seriousness of these issues, and the complexity of the issues that have to be
addressed for this hotel, please provide us with that information immediately. Pending its
receipt, Wyndham continues to perform its obligations under the Hotel Management Agreement,
regards the SDNA as an agreement in full force and effect, and reserves all rights.
Very truly yours,
'i .ano
D Wyndham Hotel Management, Inc.
CH27972466.hIO.12.09

BAI{E~
DONELSON
J3EARMA;-.J. CALDWELL
&. BERKOWITZ. PC
JOliN H. ROWLAND.
[)irect Dial: 615.726.5544
[)irect Fax: 615.744.5544
E-Mail Address:jrowlaml@bakerdonclson.com
Jon C. Vigano
Schiff Hardin LLP
6600 Sears Tower
Chicago, IL 60606
October 13,2009
BAKER DONEI.SON CE~TER
,UlTF. 1000
l11 COMMERCE ,TREET
N,SBVILLf.. IT::"'IESSH 171r.1l
PHO"!' 615.716 ',6(0
FAX: 615.716.0464
'.1,IIUNG ADDRCS,'
i' O. BOX 1~()611
"AS!!'11LLf.. Tf""E"~l:I.: 17119
www.Jukertlt)ut.tsotl.(.om
Via E-Mail tojvigano@Schiffbardin.com
Re: Wyndham Drake Oak Brook Hotel
Dear Jon:
This is in response to your letter to me dated October 12, 2009. We have previously
refuted your notion that Regions Bank ("Regions" or the "Bank") had any obligation to notify
Wyndham Hotel Management, Inc. ("Wyndham") of the transfer of its Loan and the Loan
Documents to Crestmoor One, LLC ("Crestmoor"). Regions simply disagrees with your reading
and interpretation of the SNDA. As we have pointed out repeatedly, Crestmoor was formed as a
special purpose entity ("SPE") in an attempt to limit Regions' exposure to third-parties (plimarly
vendors and suppliers) arising as the result of the owner's actions, the ensuing receivership
proceeding initiated by the Securities and Exchange Commission, and the detriorating financial
condition of the property. The timing of the formation of Crestmoor coincided with the
relinquishment of the hotel propery from the Wextrust Receivership estate. The Bank has not
released its interest in the property. There has been no intent. to conceal anything from
Wyndham at any point in this process.
The Bank's fonnation of an SPE was simply prudent planning in the event Regions
decided to take title to the property, and is a routine course of action in distressed single asset
situations. As we are sure you are aware, two parties asserting mechanics liens against the hotel
commenced foreclosure proceedings against the property prior to the Bank bringing its own
action. The commencement of the initial foreclosure action brought some amount of urgency to
an already difficult situation. Crestmoor took no action until the Loan and Loan Documents
were assigned to the SPE in late July in furtherance of Regions' decision to move forward with
foreclosure.

Jon C. Vigano
October 13, 2009
Page 2
Given the continuing deterioration of the property, the grim financial outlook provided by
Wyndham, the overall condition of the hospitality market, the lack of a viable purchaser, and the
fact that two creditors had started foreclosure proceedings, the Bank believed it necessary to take
steps to protect its interest in the property, while attempting to minimize a continuing financial
outlay that had already run into the hundreds of thousands of dollars. Based on the projections
provided by Wyndham, the Bank could not see any benefit to providing additional, long-term
funding of a detriorating asset. As of late July, these steps included negotiation of an agreement
with Wyndham to terminate the SNDA and Management Agreement and (subject to that
agreement) proceeding with its own foreclosure action. As you know, Illinois law calls for the
appointment of a mortgagee in possession pending a judgment of foreclosure. For the reasons
previously discussed, Regions did not want to be named mortgagee in possession pending the
foreclosure.
While it may not have been necessary to do so, the Bank kept Wyndham apprised of its
overall intentions as it moved toward the decision to foreclose. Certainly, the Bank viewed the
termination agreement with Wyndham as a necessary component to moving forward with the
foreclosure and sale process. In light of the parties' prior discussions, and Wyndham's
knowledge that the Bank was proceeding with a foreclosure action, the Bank does not understand
Wyndham's recent attempt to circumvent the parties' prior agreement. First, Regions does not
understand how a lack of notice concerning the assignment of the Loan and Loan Documents to
Crestmoor (even if it was required) would result in damage to Wyndham. Second, Regions
provided consideration for the agreement to terminate the contracts with Wyndham. To the
extent Wydham chooses to rescind that agreement, it would be obligated to return the $180,000,
and to replace the funds pledged to Regions in the FF&E account.
From Regions' perspective, the ultimate goal is the sale of the hotel. As to those efforts,
Regions has been contacted by a number ofparties who have expressed interest in purchasing the
property at very, very deep discounts. To date, none of those discussions has yielded a letter of
intent, much less a definitive purchase agreement. The marketing process was ongoing at the
time the parties negotiated their agreement to terminate the SNDA and Management Agreement
and that process has continued based on that agreement. Indeed, one reason Regions engaged
Wyndham concerning termination was the realization that it would be easier to sell the hotel
without agreements in place that had been negotiated by prior ownership. Given the recent
history attached to the property, it seemed likely that a new owner would seek a "fresh start",
which would include the ability to re-flag the hotel. This fact, along with the other matters set
out above, was discussed with Wyndham during the negotiations concerning the termination of
the existing agreements, and is one reason Regions agreed to provided an additional $180,000 in
funding in August. There was no request by Wyndham that Regions suspend or limit its sales
efforts while Wyndham wound down operations. Regions proceeded with its efforts in reliance
on the agreement it had made with Wyndham concerning ternlination, and with the
understanding that it would be able to convey its rights in the property free and clear of any prior
agreements between the owner and Wyndham.
Regions requests that Wyndham honor its agreement and enter into the termination and
mutual release. Unless this situation can be resolved quickly. Wyndham's decision not to honor

Jon C. Vigano
October 13, 2009
Page 3
its prior agreement is likely to have an impact on Regions' efforts to market and sell the
property. In addition, the Bank is concerned that the reversal of Wyndham's commitment will
result in further detrioriation of the asset, as Regions was making every effort to protect its
security position consistent with a projected October 30 shutdown.
The Bank is prepared to work to resolve what appears to be a misunderstanding
concerning the mechanics of the pending foreclosure action. To this end, Regions is prepared to
meet with Wyndham at the parties' convenience to the extent Wyndham believes such a meeting
would be productive.
If you have questions or wish to discuss further, please do no
JHR:srs
cc: George Patton
Randal Mashburn
Kenneth P. Ezell, Jr.
Gerald Lurie
o contact me.

REQUEST FOR ADMISSION - DEMAND FOR DISCHARGE OF MORTGAGE (Regions Bank)

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