IN THE DISTRICT COURT OF MONTGOMERY COUNTY

STATE OF MARYLAND
DRAFT PROVIDED BY 3 PARTY – NOT GUARANTEED TO BE A FULL
RD

EXAMPLE
Wells Fargo Home Mortgage., )
Plaintiff and defendant on )
counterclaim, )
)
Vs. ) Case No. 381800-V
)
John Doe, )
Defendant and )
counterclaimant, )
______________________________________)

AFFIDAVIT

I, John Doe, of lawful age and competent to testify state as follows based on my own personal
knowledge:
1. I am not in receipt of any document which verifies that I have a contract with Wells Fargo
Home Mortgage.
2. I am not in receipt of any document which verifies that I owe Wells Fargo Home Mortgage
money.
3. I am not in receipt of any document which verifies that Wells Fargo Home Mortgage
authorized suit against me or is even aware of it.
4. As the result of Dewey Cheatum’s pattern of acts against me, I have been damaged
financially, socially, and emotionally.
___________________________
John Doe

STATE OF MARYLAND INDIVIDUAL ACKNOWLEDGMENT

COUNTY OF MONTGOMERY MARYLAND Form

Before me, the undersigned, a Notary Public in and for said County and State on
this ____ day of ________, 2017, personally appeared __________________________
to me known to be the identical person who executed the within and foregoing instrument
and acknowledged to me that he executed the same as his free and voluntary act.
Given under my hand and seal the day and year last above written.
My commission expires __________ ________________________ Notary Public
 Objections

The most powerful and useful words you’ll ever learn to use are, “I object.” An
objection must have grounds, such as lack of foundation or leading the witness, but most
of the time we will use objections to prevent attorneys from giving putative testimony.
REMEMBER: ATTORNEYS CAN’T TESTIFY – NEVER!!!! When an attorney
begins to testify say, “I object,” and quickly follow with the grounds for the objection,
which is counsel is attempting to testify for a witness not in appearance. If you are
overruled a third time on your objection say, “I enter an exception to the court overruling
my objection and demand proof of claim.” The matter should be reset for appearance of
the witness, but what usually happens is the court allows hearsay. IF YOU HAVE A
COURT REPORTER PRESENT, WHICH YOU SHOULD HAVE ANYTIME THERE
IS A SUBSTANTIVE QUESTION TO BE DETERMINED, the court will be procEeding
in clear absence of all jurisdiction and subject to suit for damages in its’ individual
capacity.
 IN THE SUPERIOR COURT OF MONTGOMERY COUNTY
STATE OF MARYLAND

Diane S. Rosenberg et al )
)
Plaintiff, )
) Case# ___________
vs. ) NOTICE OF LIS PENDENS
John O. Doe and )
Jane Doe, )
Defendants. )
____________________________________)

NOTICE OF LIS PENDENS

BRIEF IN SUPPORT

The above referenced action to take the property located at 1234 Farmville Lane,
Damascus, Maryland, is subject to a pending action in Montgomery County Circuit Court,
Montgomery County, Maryland, attached as exhibit “A.” Service of process has been made on
Diane S. Rosenburg, defendant in the Montgomery County Circuit Court action, attached as “B.”
Third parties are hereby bound that any interest they may acquire in the property
located at 1234 Farmville Lane, will be subject to the outcome of the Montgomery County
action attached.

Prepared and submitted by: _________________________________________________

John O. Doe and Jane O. Doe
1234 Farmville Lane,
Damascus, Maryland 334455
(240)333-4892

AFFIDAVIT

I, John O. Doe, also known as YK Doe of lawful age, being first duly sworn, upon oath state as
follows:
1. I, hereby give notice that on June 30th 2017, I filed a petition in the Circuit Court of
Montgomery County, Maryland, case number 434085V, styled as John O. Doe, a.k.a. YK Doe,
Plaintiff, v. Diane S. Rosenberg, Defendant, which action is
pending in such cause in said Court in which action various issues have been raised
which affect Diane S. Rosenberg’s interest in the title to the property located at 1234 Farmville
Lane, Damascus, Maryland. Ms. Rosenberg is in receipt of service.
2. The property located at 1234 Farmville Lane, Damascus, Maryland, is of a
character to be subject to the principle of Lis Pendens.
3. That 1234 Farmville Lane, Damascus, Maryland, is sufficiently described in and
identified in the above styled case and is in fact the res of the pleadings attached so that
there can be no mistake regarding what property is in question and whether that property
is subject to the outcome of the attached pleadings.
4. The Court in the above styled case has jurisdiction of John O. Doe and
Jane O. Doe, and also of the property.
__________________________________
John O. Doe

Before me, the undersigned, a Notary Public in and for said County and State, on
this ____ day of ________, 2017, personally appeared John O. Doe to me known to
be the identical person who executed the within and foregoing instrument and
acknowledged to me that he executed the same as his free and voluntary act.
Given under my hand and seal the day and year last above written.
My commission expires __________ ________________________ Notary Public
John Doe and Jane Doe
1234 Farmville Lane
Damascus, Maryland 334455
(240) 333-4892

John Doe and : MARYLAND CIRCUIT COURTS

Jane Doe :
Plaintiffs, : DIVISION OF:
Vs. : MONTGOMERY COUNTY
: Docket No. 434085V
WELLSFARGO HOME MORTGAGE, : Civil Action
Defendant. :
: PLAINTIFF'S MOTION FOR
: PRELIMINARY INJUNCTION AND
: APPLICATION FOR AN ORDER
: REQUIRING THE DEFENDANT TO SHOW
: CAUSE WHY THE INJUNCTION SHOULD
: NOT BE GRANTE
____________________________________

John Doe and Jane Doe, plaintiffs in the above styled case and defendants in civil case 333444-
V, In the District Court Of Montgomery County State of Maryland, under (U.S.Dist.Ct.Rules
Md. Admis Rule 705. Rule 705 )authority of NJCR rule 4:52, et seq., move the Court enjoin
the (Monouth) Montgomery County Sheriff from removing John Doe and Jane Doe from their
residence at 1234 Farmville Lane, Damascus, Maryland 334455, also identified as Montgomery
County, District-12 Account Number 0343604, and further restrain and enjoin WELLSFARGO
HOME MORTGAGE., or WELLSFARGO HOME MORTGAGE.'s representative from any act
to remove John Doe and Jane Doe or take possession of the property located at 1234 Farmville
Lane, Damascus, Maryland 334455, until such time as John Doe and Jane Doe's petition
(attached) can be adjudicated on its merits.

BRIEF IN SUPPORT
1. It is not now, nor has it ever been John Doe and Jane Doe's intention to avoid
paying any obligation that John Doe and Jane Doe lawfully owe.
2. Dewey, Cheatum, and Howe Diane S. Rosenberg, purporting to act on behalf of
WELLSFARGO HOME MORTGAGE., have repeatedly refused to document and verify an
obligation which John Doe and Jane Doe may owe WELLSFARGO HOME MORTGAGE., as
required by law.
3. John Doe and Jane Doe will suffer irreparable harm by denial of this
preliminary injunction. John Doe and Jane Doe have lived at 1234 Farmville Lane, Damascus,
Maryland 334455, for many years together with their children. . John Doe and Jane Doe will
lose their abode and suffer irreparable harm by denial of this preliminary injunction. John Doe
and Jane Doe will suffer insult, degradation, and deprivation of personhood by denial of this
preliminary injunction.
4. John Doe and Jane Doe are likely to prevail in the attached petition. The
record in the underlying case makes John Doe and Jane Doe's averments undeniable.
5. Public interest will not be impaired by granting this preliminary injunction.
The public interest will be impaired by denial of John Doe and Jane Doe's preliminary injunction
by public awareness that Doe s can be victimized by those who declare
themselves to be of a superior class.
6. John Doe and Jane Doe have no other remedy at law to protect themselves
from parties records show have conspired to deprive them of their most fundamental
rights.
7. Denial of John Doe and Jane Doe's preliminary injunction will cause John Doe and Jane Doe
to bear a greatly unbalanced harm. WELLSFARGO HOME MORTGAGE.'s harm would be
delayed possession. John Doe and Jane Doe's harm will be loss of abode, damage to reputation
and character, and assault on personhood.
8. Denial of John Doe and Jane Doe’s preliminary injunction goes beyond
economic injury.
9. The cost to the court on error later corrected to the favor of WELLSFARGO HOME
MORTGAGE., is not as great as the cost to the Court for error later corrected to John Doe and
Jane Doe's favor.
10. Granting John Doe and Jane Doe's Motion for Preliminary Injunction
conserves the property no matter who prevails. Denial of John Doe and Jane Doe 's. Motion for
Preliminary Injunction directly affects the property by reducing it to a status
of a bell which cannot be “unrung.”
Maryland rules governing civil practice require this Court to conduct a show
cause hearing requiring the defendant to appear and be recorded verbatim. Ideals of
substantial justice and fair play require this Court grant John Doe and Jane Doe interim relief
until their complaint can be adjudicated.

Prepared and submitted by: _________________________________________

John Doe and Jane Doe

Writ of Mandamus
Issues from a court of superior jurisdiction can be directed toward a private or
municipal corporation, or any officer of a corporation, to an inferior court, or public
officer commanding the performance of a particular administrative act or restoration of
right deprived of.