Upon information and belief, the alleged Note and Mortgage and other loan documents, were induced by the fraud of the Plaintiff and its predecessors in interest and its co-conspirators, and are therefore void and unenforceable. Each one of the affirmative defense will have a lengthy explanation as to what is wrong with the foreclosure summons and why. 20. R. Civ. Contesting a judicial foreclosure lawsuit by answering the complaint with affirmative defenses can buy you time to pursue a solution like a loan modification. Before filing a foreclosure lawsuit, lenders should assess the loan file and history to spot any possible defenses, and take them into consideration when deciding how to proceed in collecting the loan. Lets say your friend signs a note that says this other guy can take the $20.00 payment on his behalf. This is especially helpful when trying to get leftover debt waived. We are a debt relief agency. Subject Guide Ulysses Jaen Contact: Adding Affirmative Defenses When Responding to a Foreclosure Summons Phone: (407) 476-4372 Orlando Foreclosure Attorney Orlando, Florida 32801 Foreclosure Attorney Michael Stites Speak to an Attorney: Relax. Barak's Answer and Affirmative Defenses. There were a total of 12 affirmative defenses made against the plaintiffs claim. What is an affirmative defense? A foreclosure is either nonjudicial or judicial depending on state law and, in some cases, the particular circumstances. A seasoned foreclosure defense attorney is equipped with an arsenal of affirmative defenses that may be of . Standing requires that the party prosecuting the action have a sufficient stake in the outcome and that the party bringing the claim be recognized in the law as being a real party in interest entitled to bring the claim. What Exposure Does a Business Have to Attorneys Fees Under the FCCPA and the FDCPA? BANKS CAN ONLY LEND MONEY. In some states, the information on this website may be considered a lawyer referral service. If you write that 50% of all homes in Florida are in foreclosure, readers would want to know where you got that number from. 4. 2. Neither the exhibits attached to Plaintiffs Complaint nor the allegations of the Complaint are sufficient to demonstrate standing. . To increase chances of success in foreclosure, lenders should be aware of what these defenses are and how to overcome them. Once the foreclosure complaint is served on the borrower, the borrower will have 20 days to file an answer and assert affirmative defenses (if any). They should have an actual claim to the home they are trying to foreclose on. Plaintiff does not have standing to bring this action. To learn more about this, see our blog: Floridas Second DCA: Florida Law Remains That Plaintiffs in Foreclosure Actions Must Have Standing at the Time of Filing Suit. 7. FIRST AFFIRMATIVE DEFENSE (Failure to State Cause of Action) Defendants allege that the Complaint, and each and every purported cause of action contained therein, fails to state facts. 3d 317, 319 (Fla. 4th DCA 2018) (Giving a notice of default is a condition precedent to foreclosure in most residential mortgages.). . For example, in a foreclosure complaint the plaintiff will charge that you haven't been paying your mortgage and they're entitled to foreclose because of that. The judicial foreclosure process starts when a lender sues a delinquent borrower in the county where the property is located. Some of the most common affirmative defenses used in foreclosure cases are: The plaintiff (bank) must prove that they are the ones legally entitled to foreclose on you. We help people file for bankruptcy relief under the Bankruptcy Code. For example, if you aren't actually delinquent in payments, that's a defense. You tell the Court your defenses when you Answer the Summons and Complaint or when you ask the Court to Vacate a Default Judgment. Accordingly, lenders should avoid unscrupulous practices, overreaching, concealment, trickery, or other unconscientious conduct.. If the HOA improperly records the lien or doesn't record the lien at all, you might have a defense to the foreclosure in a state that requires recording. Reversed and Remanded for Further Proceedings Consistent with this . An affirmative defense in a civil lawsuit is a fact that defeats or mitigates the consequences of a charge. The Plaintiff does not prove that it owns, holds, or has the right to enforce the mortgage. Ann. If your foreclosure is nonjudicial, the process won't go through the court, and you won't receive a complaint or summons, or have an opportunity to file an answer. - We Help Stop Home Foreclosure and Remove Debt Liability-. For example, the complaint will describe the mortgage (or deed of trust), the promissory note, the property to be foreclosed, the default, the amount due, as well as list the defendants and describe their interest in the property. 462 So.2d 1178, (FLA. 3d DCA 1985). PLANTIFF DOES NOT HAVE STANDING PLAINTIFF IS NOT REAL PARTY IN INTEREST: 2. his entitlement to prosecute a claim in Florida courts rest exclusively in those persons granted by substantive law, the power to enforce the claim. During the transport everything was stolen. the bank to notify you within a certain amount of time of your delinquency and in a specific manner prior to filing a foreclosure action. Common Defenses to a Foreclosure Action in New Jersey. This form and instructions are NOT a substitute for legal advice. Lack of Standing section 1601 et seq. Mortgage Loan Instrument or Personal Property; what really got securitized? It's possible to respond to a summons by preparing an answer to the complaint "pro se" (without hiring an attorney). Defendant hereby denies each and every other allegation in all . If the note does not name the plaintiff as the payee, the note must bear a special endorsement in favor of the plaintiff or a blank endorsement. 3d 170, 173 (Fla. 4th DCA 2012). So how does Kumar Corp. V Nopal Lines help our case? Payment. Plaintiff is required to suspend litigation until verification of the debt at issue. If the lender is pursuing a foreclosure outside court, you can challenge a non-judicial foreclosure by initiating a lawsuit to stop the process until a court reviews the foreclosure. Of course, a town does not live on spas alone, as much as it would like to do so. They would have unclean hands since it was their fault you are in foreclosure. Legal information is NOT the same as legal advice the application of law to an individuals specific circumstances. 5 As such, it is defenses may not. Acquisition Corp., 51 So. If your lender deceived you, acted unfairly, or failed to disclose required information, you may be able to challenge foreclosure because of it. ABC Mortgage and/or its agents made false statements and/or omissions regarding a material fact;iv. Answer 3 quick questions to see if you have a foreclosure defense case. and Regulation Z section 226 et seq. During the foreclosure action, and prior to entry of a final judgment, lenders . Service was made by delivery of the . Failure to Provide FDCPA Notice. by, interalia:a) Failing to provide the Housing and Urban Development (HUD) special information booklet, a Mortgage Servicing Disclosure Statement and Good Faith Estimate of settlement/closing costs to Defendants at the time of the loan application or with three (3) days thereafter) Failing to provide Defendants with an annual Escrow Disclosure Statement for each of year of the mortgage since its inception;c) Giving or accepting fees, kickbacks and/or other things of value in exchange for referrals of settlement service business, and splitting fees and receiving unearned fees for services not actually performed;d) Charging a fee at the time of the loan closing for the preparation of truth-in-lending, uniform settlement and escrow account statements. We go on to define what standing is: Standing requires that the party prosecuting the action have a sufficient stake in the outcome and that the party bringing the claim be recognized in the law as being a real party in interest entitled to bring the claim. This document is then served to the borrower along with a summons. 702.01. Some of the most common defenses raised by a borrower include: . Corp. v. TSE Plantation, LLC, 301 So. Here we reference a previously ruled case to enforce our claim: Kumar Corp. v Nopal Lines, Ltd, et. The plaintiff must also demonstrate that it holds the note and mortgage at the time of the trial. 8(c) requires a party to "set forth affirmatively . There are many different affirmative defenses that can be used when responding to a foreclosure complaint. 3. Fla. Stat. Fraud. 501.201, et seq. What to Do With the Answer erroneous. The appropriate mailing address can be found in the complaint, usually under the attorney's signature. 3d at 251. [6] The ruling of Kumar Corp. v Nopal Lines reinforces your argument. FRAUD STOPPERS turnkey Quiet Title Lawsuit package or Wrongful Foreclosure Lawsuit package includes a court ready complaint (petition for damages), Bloomberg Securitization Audit, Expert Witness Affidavit, Application for Temporary Restraining Order (to stop a foreclosure sale or stop an eviction), Lis Pendens (to cloud the marketability of the title to the real property), and Pro Se legal education material that can show you how to win a Quiet Title Lawsuit or win a Wrongful Foreclosure Lawsuit. Kumar had not received payment from Nava and was not carrying insurance for the items being sold. Lenders should also keep a copy of the notice of default letter in their loan file as evidence of substantial compliance. CONTACT Tell Our Attorneys What Happened Open M - F 9am to 5pm Orlando FL, 32801 HOME 12. Violation of TILA. Jallali v. Christiana Tr., 200 So. If an allegation is admitted, the court will accept it as fact. See our About Us page for our qualifications and experience. The header is numbered and used to state the first defense and helps keep track of each affirmative defense. The Trustee's Foreclosure Action is Involuntarily Dismissed Following a Non-Jury Trial. Bartram v. U.S. Bank Nat. 673.3091 provides only for re-establishment of negotiable instruments as defined under Fla. Stat. In JPMorgan Chase Bank, N.A. An affirmative defense is a legal defense to the foreclosure action which must be included in the answer. When your bank serves you with a foreclosure complaint for not paying your mortgage, you have a right to answer it and deny its charges, which you should. Jimerson Birr welcomes inquiries from the media and do our best to respond to deadlines. McLean v. JP Morgan Chase Bank Nat. This is a reminder that a client's state court foreclosure action must be tended carefully to avoid collision with the doctrines of res judicata, claim preclusion and . If allowed by state law, the complaint might also ask for a deficiency judgment if the proceeds at the foreclosure sale don't fully cover the total debt amount. If you are interested in speaking to a Jimerson Birr lawyer or want general information about the firm, our practice areas, lawyers, publications, or events, please contact us via email or telephone for assistance at (904) 389-0050. This time should be used to work out a plan with your lender if you are planning on keeping your home. If the ownership of your mortgage isn't clear, you may be able delay foreclosure. An affirmative defense wouldn't deny that (though the answer probably would), but it would basically say that it doesn't matter for some reason, like the plaintiff doesn't have the right to foreclose. 846, 848 (Fla. 1928) (quoting Indian River Mfg. Fla. Stat. This is some of the paperwork they are referring to. In its answer, Barak asserted numerous affirmative defenses. The common affirmative defenses are fraud, undue influence, lack of notice required under the mortgage, standing, payment, and duress. It allows you to create reference points to when you make claims. Plaintiff should have included a count to reform the mortgage, to help explain these material ambiguities, which would have in turn, created a more definite statement. If you think the plaintiff has not written any part of their cause or causes of action, you can use this defense. the affirmative defense and (2) the affirmative defense fails either because the affirmative defense cannot be established or because the affirmative defense has no bearing on the claims asserted. 3. To fight a nonjudicial foreclosure in court, you'll need to file your own lawsuit. An affirmative defense is used to justify, or provide an explanation for, the defendant's illegal conduct. 607.1502(1) and 607.1501(a), (g) and (h).The complaint fails to join indispensable parties, specifically the loan originator and the loan servicer(s) and the complaint fails to adequately show the chain of title demonstrating that Plaintiff is in fact the real party in interest with standing to bring this action. What Fees Are You Charged in Foreclosure? 3d 351, 352 (Fla. 1st DCA 2014) (A plaintiff alleging standing as a holder must prove it is a holder of the note and mortgage both as of the time of trial and also that the (original) plaintiff had standing as of the time the foreclosure complaint was filed.). They used a transport company (Nopal) to transport the TV sets and parts to Venezuela. 2d 297, 299 (Fla. 3d DCA 1982)(An indispensable party [is] one without whom the rights of others cannot be determined.). THIS SITE IS NOT INTENDED TO BE MISCONSTRUED AS LEGAL ADVICE. The general rule in equity is that all persons materially interested, either legally or beneficial, in the subject-matter of the suit, must be made parties either as complainants or defendants, so that a complete decree may be binding upon all parties. 2. Failure to Join Indispensable Party. Common Defenses in a Foreclosure Case A defense is a reason why the plaintiff should not win the case. A 2008 foreclosure action was discontinued by a stipulation dated January 23, 2013, which was so-ordered by the Supreme Court, wherein the parties agreed, inter alia, that: (1) the defendant was served with a copy of the summons and complaint; (2) the defendant would withdraw his motion; (3) the action would be discontinued without prejudice and Failure to Timely Serve Complaint.a) Complaint was filed on February 13, 2008.b) However, Defendant was served on July 3, 2008.c) Pursuant to Fl. The order and judgment of foreclosure and sale, upon an order of the same court entered December 5, 2017, inter alia, granting those branches of the plaintiff's motion which were for summary judgment on the complaint insofar as asserted against that defendant, striking the answer and affirmative defenses of that defendant, and for an order of Summonses are issued for each defendant who's named in the foreclosure lawsuit. Upon information and belief, Plaintiff and/or its predecessor(s) in interest had unclean hands in their course of dealing with Defendant because the several facts alleged herein below, and Plaintiff also wrongfully refused reinstatement. You will also want to reference Florida statutory laws and the laws of civil procedures with your other affirmative defense arguments. Therefore, the trial court's entry of summary judgment was. this happens when the bank files a foreclosure action and the homeowner is subject to a forbearance agreement, mortgage modification, the bank . of a defense, it should not be dismissed" (Federici v Metropolis Night Club, Inc., 48 AD3d 741, 743 [2d Dept 2008]). The original lender will usually have no problem proving standing. If you do not include an affirmative defense in your answer, it cannot be raised at a later date to defend against your case. Plaintiff brought this action without providing notice to Defendant of Defendants right to dispute the debt, pursuant to the Fair Debt Collection Practices Act. Mr. Doe suffered damages in justifiable reliance on the representation. 718.116(b), 720.3085(2)(c). Based on this, lenders, or the holder of the note and mortgage, should be sure to review the loan documents and provide borrowers with the required notice of default before filing a foreclosure lawsuit, or risk having the foreclosure lawsuit dismissed. Charles B. Jimerson Created by the Western Allies in 1947, it was run by the U.S . Above is only one part of the first affirmative defense but I will break down what it is saying piece by piece. An "affirmative defense" is a reason why a judgment shouldn't be granted in favor of the lender. The Bad Aibling Station (abbreviated BAS, also known as Field station 81, which had an official designation as the 18th United States Army Security Agency Field Station, or as the pseudonym Hortensie III) is a satellite tracking station operated by the German intelligence agency Bundesnachrichtendienst (BND) in Bad Aibling, Bavaria.. Different defenses exist in a foreclosure action: Can those defenses actually get me out of the mortgage debt? PNC Bank, Natl Assn v. Smith, 225 So. Plaintiff has unclean hands due to its actions described below and therefore is prohibited from obtaining equitable relief of foreclosure. If plaintiff meets that burden of production, the burden then shifts to defendant to demonstrate the existence of a triable issue of material fact. Rescission. All initial consultations are completely free and we can contact the same or following business day. Please refresh the page and try again, By clicking "Find a Lawyer", you agree to the Martindale-Nolo. We are applying the same concept to this affirmative defense. Here is an excerpt of us raising it for a Florida client: Standing. For example, the complaint will typically ask the court for the right to sell the property and apply the proceeds of the sale to the mortgage debt. Affirmative Defenses Must Be Supported. The lender then has to prove its case to the court before it will be allowed to complete a foreclosure sale. Defendant denies any and all other allegations and statements set forth by Plaintiff unless specifically admitted herein. The facts and law in each case are different. (e) Effect of Failure to Deny. You may schedule a free consultation at any time. While a defendant may also raise affirmative defenses or file a counterclaim, a defendant cannot use this response as a means to attack the sheriff's . 3d 1176, 1179 (Fla. 2d DCA 2010) (Because J.P. Morgan did not own or possess the note and mortgage when it filed its lawsuit, it lacked standing to maintain the foreclosure action.). Assn v. J.P. Morgan Mortg. However, borrowers usually default more than once. Include a numbered paragraph response for each of the numbered paragraphs of the complaint. . In order to make sure that you understand all of your rights and responsibilities in a foreclosure action, you should seek legal advice. Upon information and belief, Plaintiff and/or its predecessor(s) in interest violated various provisions of the Home Ownership Equity Protection Act(HOEPA) pursuant to 15 USC 1639 et seq. Pro. TILA is the Truth in Lending Act which is codified at 15U.S.C. The Borrower's Answer and Affirmative Defenses. . To the extent that state law would prevent a RESPA Kumar Corp. v Norpal Lines, Ltd, et. Whoever is assigned the note and mortgage is the one with the right to foreclose. In Criminal and Civil law, an Affirmative defense is a fact or set of facts that if proven by the defendant, nullifies or mitigates the legal consequences of the defendant's otherwise unlawful conduct. A cause of action is a legal theory upon which a lawsuit can be based. Shahar, 125 So. Luckily for lenders, the five year timeline starts for each separate and distinct default. . It will also include exhibits, such as a copy of the note and mortgage. 11. Further, the principal balance claimed as owed is not owed and is the wrong amount; the loan has not been properly credited or amortized. Section 1601 etseq. Look on the summons to find the court's address. The answer should include responses to each of the claims the lender makes it its complaint. With a judicial foreclosure, the foreclosure goes through the state court system, and a judge is required to sign off on the process. 4521.34. FAILURE TO FILE NON-RESIDENT COST BOND IN COMPLIANCE WITH FLORIDA STATUTE 57.011: 4. The clear language in the mortgage names MERS as a mortgagee; this would, at the very least, create and ambiguity pertaining to a material fact upon which Plaintiffs claim is based. Hertz Corp.v. Unconscionability. Under contractual law, any ambiguities shall be construed against the drafter, which in this case would be an interpretation against the Plaintiff and in favor of the defendant. What Are Statutory Damages Under the FCCPA and the FDCPA? However, minor defects in the description are not usually sufficient to defeat a mechanic's lien claim. The best way for lenders to succeed in their foreclosure lawsuit is to ensure the borrower cannot succeed on possible defenses. Developing a strong mortgage foreclosure defense strategy in Ohio is key to successfully protecting your home against a bank's attempted foreclosure. FAILURE OF GOOD FAITH AND FAIR DEALING: UNFAIR AND UNACCEPTABLE LOAN SERVICING. A default judgment means that you automatically lose the case by failing to answer, and the lender will be granted the relief sought in the complaint. not include affirmative defenses demanding a response. The courts will want your reasoning why you deny an allegation. For example, Florida courts have found that a lender came to the court with unclean hands when it altered the borrowers income information on the loan application, without the borrowers knowledge, in order to qualify the borrower for a loan, which resulted in a payment increase of 50%. The information provided on this site is not legal advice, does not constitute a lawyer referral service, and no attorney-client or confidential relationship is or will be formed by use of the site. In a nonjudicial foreclosure, the property can be sold without any, or little, court oversight. These violations provide an extended three year right to rescission and enhanced monetary damages for the Defendants. The notice of lis pendens is a document that is filed with the county clerk in the land records to provide notice to the public, subsequent lienholders, and potential purchasers of the property that a foreclosure suit encumbers the property. A "defense" is a reason why the foreclosure lawsuit should not have been filed in the first place. In 1936 a military airfield was established by the German National . 5. Facing Foreclosure? Kumar sued Nopal (the carrier) to recover the monetary loss of the stolen items. Responding to a foreclosure summons comes up in a judicial foreclosure, but not a nonjudicial one. PLANTIFF DOES NOT HAVE STANDING PLAINTIFF IS NOT REAL PARTY IN INTEREST: Plaintiff does not have standing to bring this action. Plaintiff lacks standing to prosecute the Complaint. For instance, the borrowers will be named defendants, along with any lienholders, like second mortgage holders and creditors with judgment liens, that are of record when the suit is filed. The general rule in equity is that all persons materially interested, either legally or beneficial, in the subject-, To begin, there is nothing attached to the Complaint which establishes that Plaintiff, WELLS BANKER, AS SUCCESSOR TRUSTEE UNDER SUPERSTAR MORTGAGE FUNDING TRUST, SERIES 2010-, DISMISSAL OF COUNT TO REESTABLISH PROMISSORY NOTE. Neither the exhibits attached to Plaintiffs Complaint nor the allegations of the Complaint are sufficient to demonstrate standing. A notice of lis pendens, Latin for "suit pending," is recorded in the county records. Plaintiff does not have standing to bring this action. 95.11(2)(c). That, in legal terminology, is called standing. And most states require the plaintiff to own and hold the mortgage and note at the time they sue. Pick & Zabicki LLP v Wu 2017 NY Slip Op 30687(U) April 4, 2017 Supreme Court, New York County Docket Number: 155702/2016 Judge: Gerald Lebovits is interesting because, although a generic attorney-fee claim with generic defenses, it is a very complete generic listing. Problems arise when the mortgage and note are assigned to servicers, trustees, or holders and the right documentation or original note can't be found. Willey v. W. J. Hoggson Corporation, 90 Fla. 343, 106 So. Kiefert v. Nationstar Mortg., LLC, 153 So. The town was home to one of the largest listening stations in the world, a joint effort with the Americans to do intelligence work. Defenses under the TILA provisions are : The federal Truth In Lending Act (TILA) requires lenders to disclose the annual percentage rate, payment schedule, and other information about the loan. Plaintiff has failed to join an indispensable party. Prior to the enactment of Real Property Actions and Proceeding Law ("RPAPL") 1302-a, defendants waived their affirmative defense of standing in a residential foreclosure action by failing to raise that defense in an answer or a pre-answer motion to dismiss. A foreclosure by power of sale before the clerk does not resolve all matters in controversy between the parties.5 The proper mechanism to raise equitable defenses to the foreclosure is by filing an action before the superior court to enjoin the foreclosure sale under G.S. In the context of foreclosure lawsuits, the plaintiff will have unclean hands if it uses unscrupulous practices, overreaching, concealment, trickery, or other unconscientious conduct. Shahar v. Green Tree Servicing LLC, 125 So. 1. A "statute of limitations" sets a deadline for filing a legal action, like a foreclosure. 19. Managing Partner Defending against a foreclosure for a client Lawyer Manual Common defenses to foreclosure Loan documents and the foreclosure complaint must be carefully reviewed to determine if there are any equitable or technical defenses. 3d 251, 253 (Fla. 4th DCA 2013). Id. Connect with me on LinkedIn. Failure to State a Claim for Which Relief May Be Granted.a) Plaintiff filed a claim to re-establish a lost note.b) Plaintiff claims the right to re-establish such note under Fla. Stat. We've helped 75 clients find attorneys today. Co. v. Wooten, 37 So. However, an attorney might be able to call attention to defenses or flaws in the lender's complaint that you don't notice. Can I Defend Against a Foreclosure Without a Lawyer? Remember the friend who you owed $20.00 and some other guy came up asking for payment? 9. Defendant admits that it is the owner of the property which is the subject matter of this foreclosure action. The Mortgage clearly states that, MERS is the mortgagee. With mortgagee being synonymous with lender, this statement acts to establish MERS as the original lender, rendering them a necessary and indispensable party to this action. Fraud in the Inducement.i. An indispensable party is one whose interest in the controversy makes it impossible to completely adjudicate the matter without affecting either that partys interest or the interests of another party in the action. Another common defense in foreclosure lawsuits in Florida is the lender failed to provide the required notice of default. Referencing case law and previously ruled cases is another important part when creating your affirmative defenses. Banking & Financial Services Industry Legal Blog, Floridas Second DCA: Florida Law Remains That Plaintiffs in Foreclosure Actions Must Have Standing at the Time of Filing Suit, How to Foreclose on Mortgaged Land in Different Counties. PLANTIFF DOES NOT HAVE STANDING PLAINTIFF IS NOT REAL PARTY IN INTEREST: Plaintiff does not have standing to bring this action. Unclean Hands. Typically you will reference previously ruled court cases to help your defense. What are the affirmative defenses to a foreclosure lawsuit? Kumar Corp. v Nopal Lines, Ltd was a court case that was ruled in back in 1985. An affirmative defense is a reason given by the defendant for why the plaintiff should not win the lawsuit, even if what the plaintiff says is true. 6. In Texas, defendants must assert affirmative defenses in their Answer at the beginning of the case or risk not being able to use them later. You are saying since the lender did not include an endorsement from the original lender, they have not proven the debt is actually owed to them. The same idea works with your mortgage. We've helped 75 clients find attorneys today. Plaintiff is required to notify Defendant, pursuant to 15 U.S.C 1601, et seq., that Defendant may dispute the debt and Plaintiff is required to provide verisifcation fo the debt. Another defense in foreclosure lawsuits is that the foreclosing plaintiff came to the court with unclean hands. The Mortgage clearly states that, MERS is the mortgagee. With mortgagee being synonymous with lender, this statement acts to establish MERS as the original lender, rendering them a necessary and indispensable party to this action. 8. Do Not Sell or Share My Personal Information. Usually, mortgage lenders are required by the loan documents to give borrowers notice of default as a condition precedent to bring a foreclosure lawsuit. Because the prosecutor or plaintiff has the burden of proving his case, a defendant can use a negating defense to bring . 2d 717, 720 (Fla. 1956). In each of the numbered paragraphs in the answer, the defendant must generally admit, deny, or state that there is insufficient knowledge to admit or deny the allegations for the corresponding numbered paragraph in the complaint.
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