Chase's Motion To Dismiss Schneider's 2nd Amended Complaint, Reliance On Sealed Exhibits, Schneider V JPMC 14-01047 Doc 105
Uploaded by
lschneider68Chase's Motion To Dismiss Schneider's 2nd Amended Complaint, Reliance On Sealed Exhibits, Schneider V JPMC 14-01047 Doc 105
Uploaded by
lschneider68Case 1:14-cv-01047-RMC Document 105 Filed 11/12/15 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
)
UNITED STATES OF AMERICA, et al., )
ex rel. LAURENCE SCHNEIDER, ) Case No. 1:14-cv-01047-RMC
)
Plaintiffs, )
)
v. )
)
J.P. MORGAN CHASE BANK, N.A., )
et al., )
)
Defendants. )
)
DEFENDANTS’ MOTION TO DISMISS RELATOR’S
SECOND AMENDED COMPLAINT
Pursuant to Fed. R. Civ. P. 12(b)(6), Defendants JPMorgan Chase Bank, N.A., J.P.
Morgan Chase & Co. and Chase Home Finance LLC (collectively “Chase”) hereby move to
dismiss Relator’s Second Amended Complaint. In support of this Motion, Chase relies upon the
accompanying Memorandum and the following declarations and exhibits:
1. Declaration of Jessica Dunn, and the attached Exhibit 1 (email from the National
Mortgage Settlement Monitor’s law firm to Joy Palazzo of Chase and Romeo Quinto of
Morgan Lewis & Bockius LLP);
2. Declaration of Sandra Karwhite, and the attached Exhibit 1 (Making Home Affordable
“Subsequent Certification” template) and Exhibit 2 (letter from Chase and EMC
Mortgage Corporation to Paul Heran, Program Executive, Making Home Affordable-
Compliance); and
Case 1:14-cv-01047-RMC Document 105 Filed 11/12/15 Page 2 of 3
3. Declaration of Michael M. Maya, and the attached Exhibit 1 (comparison of Relator’s
First Amended Complaint against Relator’s Second Amended Complaint).
A proposed order is attached for the Court’s convenience.
Respectfully submitted,
Dated: November 12, 2015 /s/ Robert D. Wick
Robert D. Wick (D.C. Bar No. 440817)
Christian J. Pistilli (D.C. Bar No. 496157)
Michael M. Maya (D.C. Bar No. 991742)
COVINGTON & BURLING LLP
One CityCenter
850 Tenth Street NW
Washington, DC 20001
Tel: (202) 662-6000
Fax: (202) 662-6291
Attorneys for Defendants
2
Case 1:14-cv-01047-RMC Document 105 Filed 11/12/15 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on November 12, 2015, a true and correct copy of the foregoing
motion, the supporting memorandum and declarations and the exhibits thereto, and an
accompanying proposed order were served electronically on all registered counsel of record via
ECF and are available for viewing and downloading from the ECF system.
/s/ Robert D. Wick
Robert D. Wick
COVINGTON & BURLING LLP
One CityCenter
850 Tenth Street NW
Washington, DC 20001
Tel: (202) 662-6000
Fax: (202) 662-6291
Email: [email protected]
Attorney for Defendants
