In re Carrsow-Franklin

U.S. Bankruptcy Court1/29/2015
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MEMORANDUM OF DECISION ON DEBTOR’S OBJECTION TO CLAIM OF WELLS FARGO BANK, NA

HON.ROBERT D. DRAIN, UNITED STATES BANKRUPTCY JUDGE

The debtor herein (the “Debtor”) has objected to a claim filed in this case by Wells Fargo Bank, NA (‘Wells Fargo”), Claim No. 1-2, dated September 29, 2010 (amending Claim No. 1-1), on the basis that Wells Fargo is not the holder or owner of the note and beneficiary of the deed of trust upon which the claim is based and therefore lacks standing to assert the claim.1 This Memorandum of Decision states the Court’s reasons, based on the record of the trial held on December 3, 2013 and the parties’ pre- and post-trial submissions, for granting the Claim Objection.

Jurisdiction

The Court has jurisdiction over this contested matter pursuant to 28 U.S.C. §§ 157(a)-(b) and 1334(b). Under 28 U.S.C. § 157(b)(2)(B) this is a core proceeding which the Court may determine by final order.

Background

On July 15, 2010, Wells Fargo filed its first proof of claim in this case, Claim No. 1-1, asserting indebtedness of $170,072.60, including prepetition arrears of $38,163.16. The proof of claim attached a copy of a 30-*36year note, dated October 30, 2000, payable „to Mortgage Factory Inc. in the amount of $145,850 (the “Note”), which was signed by the Debtor. The version of the Note attached to Claim No. 1-1 bears a specific indorsement by Mortgage Factory Inc. to ABN Amro Mortgage Group, Inc. (“ABN Amro”) and no other indorsements.

Claim No. 1-1 also attached a Deed of Trust made out to Malcom D. Gibson, as trustee, and an Assignment of Rents, both dated October 30, 2000, which secure the Note with the Debtor’s interest in the real property located at 2523 Crenshaw Drive, Round Rock Texas 78664 and the other collateral described therein (the “Property”). There is no real dispute that the Deed of Trust and related security documents were properly filed and recorded under Texas law; they bear the November 16, 2000 file stamp of the County Clerk of Williamson County, Texas.2 Claim No. 1-1 also attached an Assignment of Lien, dated October 30, 2000, pursuant to which Mortgage Factory, Inc. assigned its rights under the Note and related liens to ABN Amro; it, too, bears the County Clerk’s file stamp, dated November 16, 2000.

Also attached to Claim No. 1-1 was an Assignment of Deed of Trust by ABN Amro, dated June 20, 2002, pursuant to which ABN AMRO assigned “all beneficial interest in” the Deed of Trust securing the Note, together with the Note, to Mortgage Electronic Registration System (“MERS”) “as nominee for Washington Mutual Bank, FA,” which bears the Williamson County Clerk’s June 28, 2002 file stamp.

Claim No. 1-1 also attached (a) a Loan Modification Transmittal Form, (b) a Loan Modification Agreement signed by the Debtor and an officer of Wells Fargo, dated February 12, 2008, and (c) an unsigned form, with the heading “Freddie Mac,” addressed to an officer of Wells Fargo, which states that Freddie Mac has approved Wells Fargo’s request to consider a loan modification pertaining to the Debtor on certain conditions.

Finally, Claim No. 1-1 attached an Assignment of Mortgage pursuant to which MERS assigned to Wells Fargo “a mortgage” (neither rights under the Deed of Trust, nor the Note) made by the Debtor pertaining to the Note. This Assignment of Mortgage is dated July 12, 2010, which is three days before the date of Claim No. 1-1, and is executed on behalf of MERS “as nominee for Washington Mutual Bank, FA” by John Kennerty, Assistant Secretary, presumably of MERS.

In the Claim Objection, the Debtor’s counsel has represented without dispute that after reviewing Claim No. 1-1 she contacted Wells Fargo’s then counsel, who had signed Claim No. 1-1 on Wells Fargo’s behalf, with questions regarding Wells Fargo’s standing to assert the claim and followed up on July 26, 2010 with a qualified written request under RESPA, 12 U.S.C. § 2605, and a borrower’s request under TILA, 15 U.S.C. §§ 1601, et seq. Wells Fargo responded to these requests in a letter, dated August 18, 2010, in which it stated that Freddie Mac owned the Note, which Freddie Mac had already represented to the Debtor’s counsel in a July 27, 2010 email. See Exhibits N and O, respectively, to the Claim Objection.

Neither the email from Freddie Mac, the letter from Wells Fargo, nor anything else offered by Wells Fargo’s then counsel dealt with the two key issues raised by *37Claim No. 1-1, however: (i) how could Wells Fargo or Freddie Mac assert a claim under the Note when the Note was neither specifically indorsed to either of them nor indorsed in blank (and was specifically .indorsed to ABN Amro, although ABN Amro had subsequently assigned its interest therein to MERS as nominee for Washington Mutual Bank, FA), and (ii) how could Wells Fargo properly assert any rights under the July 12, 2010 Assignment of Mortgage when the person who signed the Assignment of Mortgage from MERS in its capacity “as nominee for Washington Mutual Bank, FA” to Wells Fargo was an employee of Wells Fargo (as well as of MERS),3 and there was no evidence that Washington Mutual Bank, FA authorized MERS to assign its interest in the Property to Wells Fargo? Wells Fargo and Freddie Mac’s responses to the Debtor’s counsel’s questions raised another question, though: if Freddie Mac was the owner of the loan, as both Wells Fargo and Freddie Mac contended, why was Claim No. 1-1 filed by Wells Fargo not as Freddie Mac’s agent or servicer, but, rather, in its own name? (The ownership/agency issue had practical as well as possible legal consequences because counsel for Wells Fargo contended that Freddie Mac guidelines precluded Wells Fargo from considering loan modification proposals for the Debtor.)

Before the expiration of the bar date in this case, though, Wells Fargo filed another proof of claim, amended Claim No. 1-2, dated September 23, 2010, which was the same as Claim No. 1-1 in all respects except one: the copy of the Note attached to Claim No 1-2 had a second indorsement. In addition to the specific, or special indorsement from Mortgage Factory Inc. to ABN Amro, it also had a blank indorsement, signed by Margaret A. Bezy, Vice President, for ABN Amro.

Presumably, Claim No. 1-2 was intended to satisfy the Debtor’s questions about Wells Fargo’s standing to assert a claim: as discussed below, under Texas law a person in possession of a note indorsed in blank may enforce the note and a related deed of trust or mortgage even if the noteholder does not have a valid assignment of the mortgage or deed, of trust. Nevertheless, the Debtor filed the Claim Objection, asserting several reasons why Claim No. 1-2 should be disallowed under 11 U.S.C. § 502 and Fed. R. Bankr.P. 3007, although since that time she actively pursued only two.4

First, the Debtor contended that Wells Fargo lacked standing to assert the claim because it admittedly did not own the loan upon which it was based yet filed the claim on its own behalf, not as agent or servicer for Freddie Mac. See In re Unioil, Inc., 962 F.2d 988, 992 (10th Cir.1992) (proof of *38claim “which did not even indicate [claimant’s] representational capacity much less disclose the identity of the true creditor, was defective” under Fed. R. Bankr.P. 3001(b));5 cf. In re Manville Forest Products Corp., 89 B.R. 358, 376-77 (Bankr. S.D.N.Y.1988), aff'd, 99 B.R. 543 (S.D.N.Y. 1989), aff'd, 896 F.2d 1384 (2d Cir.1990) (applying Fed. R. Bankr.P. 3003(c), which pertains to cases under chapters 9 and 11 of the Bankruptcy Code, to preclude filing of proof of claim in unauthorized capacity).

Second, the Debtor contended that the blank indorsement that appeared for the first time on the form of Note attached to Claim No. 1-2 was as improper as the purported July 12, 2010 Assignment of Mortgage to Wells Fargo executed on behalf of the assignor/nominee by an employee of Wells Fargo. As alleged' by the Claim Objection, the blank indorsement was forged in response to problems with the documentation of Wells Fargo’s right to enforce the Note, just, as the Debtor contended, the July 12, 2010 Assignment of Mortgage was manufactured three days before Claim No. 1-1 was filed in order to falsely lead the Debtor and the Court to think that Wells Fargo had an independent right to enforce a mortgage on the Property-

Wells Fargo retained new counsel,6 and the parties engaged in discovery disputes that resulted in an order compelling the deposition of John Kennerty, who by then no longer worked for Wells Fargo, see Kennerty v. Carrsow-Franklin (In re Carrsow-Franklin), 456 B.R. 753 (Bankr. D.S.C.2011), and Wells Fargo’s production of a woefully unqualified initial Rule 30(b)(6) witness. With discovery still far from complete, however, the Debtor moved for summary judgment under Fed. R. Bankr.P. 7056, primarily on the basis that Wells Fargo concededly did not own the loan yet had not filed Claim No. 1-2 in a representative capacity. Wells Fargo responded that it did not need to be the owner of the loan in order to enforce the Note and a secured claim for amounts owing under it. Instead, Wells Fargo relied, under Texas’ version of Article 3 of the Uniform Commercial Code (the “U.C.C.”), solely on being the “holder” of the Note indorsed in blank by ABN Amro that appeared for the first time as an attachment to Claim No. 1-2.7

*39In a bench ruling on March 1, 2012, memorialized by an order dated May 21, 2012, the Court agreed with Wells Fargo, concluding that, under Texas law, if Wells Fargo were indeed the holder of the Note properly indorsed in blank by ABN Amro, Wells Fargo could enforce the Note and the Deed of Trust even if it was not the owner or investor on the Note or properly assigned of Deed of Trust,8 citing SMS Fin., Ltd. Liab. Co. v. ABCO Homes, Inc., 167 F.3d 235, 238 (5th Cir.1999) (under Texas law, “[t]o recover on a promissory note, the plaintiff must prove: (1) the existence of the note in question; (2) that the party sued signed the note; (3) that the plaintiff is the owner or holder of the note; and (4) that a certain balance is due and owing on the note”) (emphasis added), and In re Pastran, 2010 WL 2773243, at *2, 2010 Bankr.LEXIS 2237, at *6-7 (Bankr. N.D.Tex., July 13, 2010) (same). See also Tex. Bus. & Com.Code § 3.301 (2014) (“A person may be a person entitled to enforce the instrument even though the person is not the owner of the instrument....”); Das v. Deutsche Bank Nat’l Trust Co., 2014 WL 1022385, at *2-3, 2014 Tex.App. LEXIS 2541, at *6-7 (Tex.App. Dallas March 5, 2014), petition for review denied, 2014 Tex. LEXIS 441 (Tex. May 30, 2014) (same); Martin v. New Century Mortg. Co., 377 S.W.3d 79, 84-5 (Tex.App. Houston 1st Dist. 2012) (same); Roberts v. Roper, 373 S.W.3d 227, 232 (Tex.App. Dallas 2012) (same); BAC Home Loans Servicing, LP. v. Tex. Realty Hldgs., LLC, 901 F.Supp.2d 884, 907 (S.D.Tex.2012) (“A holder of a note, as well as an owner, may enforce the note.”); see generally Joseph William Singer, “Foreclosure and the Failures of Formality, or Subprime Mortgage Conundrums and How to Fix Them,” 46 Conn. L.Rev. 497, 526 (Dec.2013) (“Foreclosure and Failures”) (“The prevailing view seems to be that most mortgage notes are negotiable instruments governed by Article 3 of the Uniform Commercial Code (U.C.C.) and that mortgage obligations are owed to ‘the person entitled to enforce the note’ within the meaning of U.C.C. section 3-301; that person may be different from the person who ‘owns’ the note and has the ultimate right to the economic value of the note.”); James M. Davis, “Paper Weight: Problems in the Documentation and Enforcement of Transferred Mortgage Loans, and Proposal for an Electronic Solution,” 87 Am. Bankr.LJ. 305, 322-23 (2013) (discussing the difference between the right to enforce a note under the U.C.C. and ownership of the note). For the proposition that under Texas law the holder of a note may enforce *40a deed of trust securing the note even if the deed of trust is not assigned to the noteholder or in the noteholder’s name, see Kiggundu v. Mortg. Elec. Registration Sys., 469 Fed.Appx. 330, 332 (5th Cir. 2012), cert. denied, — U.S. -, 133 S.Ct. 210, 184 L.Ed.2d 41 (2012).

The Court therefore denied the Debtor’s summary judgment motion for an order declaring that Wells Fargo lacked standing to assert Claim No. 1-2. Because discovery with respect to the bona fides of the all-important blank indorsement appearing on the version of the Note attached to Claim No. 1-2, was not complete, however, the Court scheduled an evidentiary hearing oh that issue.9

After the completion of discovery, which included the depositions of Mr. Kennerty and Mr. Kyle N. Campbell — the third witness offered by Wells Fargo to corroborate its possession of the Note attached to Claim No. 1-2 and the propriety of the blank indorsement — the Court held an evi-dentiary hearing in which it took testimony from Mr. Campbell and the Debtor. The parties earlier agreed to the admission of Mr. Kennerty’s deposition transcript in lieu of his testimony, as well as to the admission into evidence of the exhibits attached to Claim Nos. 1-1 and 1-2, as well as the original of the Note with the blank ABN Amro indorsement, a copy of which was attached to Claim No. 1-2.

Based on the Court’s review of the original of that document, the blank ABN Amro indorsement has been stamped on the last page of the Note, although it is not discernable whether Margaret A. Bezy’s signature was separately written in on the signature line or was part of the stamp. See December 3, 2013 Trial Transcript (“Trial Tr.”), at 5-6 (The Court: “So this is the second endorsement, the blank endorsement, then is a file stamp? It’s a stamp?” Mr. Dunn: “I have no personal *41knowledge, but it appears to be.” The Court: “Well, it appears to be. It doesn’t look like it’s a signature.” Mr. Dunn: “It appears to be an inked stamp.” The Court: “Right.” Mr. Dunn: “The endorsement in blank by ABN Amro does appear to have been applied by a representative.”).

While agreeing to the admission of the original version of the Note, the Debtor did not, of course, agree to the validity of the blank ABN .Amro indorsement, continuing to assert that it was forged. The Debtor also objected to the admission of certain other proposed exhibits printed from Wells Fargo’s computer file for the loan at issue, which Wells Fargo offered as business records under Fed.R.Evid. 803(6).

After post-trial briefing on the Debtor’s objection to the exhibits’ admission, the Debtor also moved to reopen the record to take further discovery of Wells Fargo based on the contention that she had unearthed withheld evidence consisting of a Wells Fargo attorney manual that supported her contention that Wells Fargo had an “indorsement team” that improperly added the blank indorsement to the Note.10

The Court granted this motion, provided that the additional discovery would pertain only to the loan and Note at issue. Several months passed until, after the Court’s inquiry, the parties replied that they were not going to present any more evidence and wanted a ruling on the merits of the Claim Objection on the basis of the evidence previously submitted.

Discussion

Because it is undisputed that (a) the Debtor signed the Note (and received the loan proceeds)11 and (b) a properly recorded lien on the Property secures the Debtor’s obligation under the Note (albeit that Wells Fargo does not rely independently on the Deed .of Trust assigned to ABN AMRO and then assigned to MERS as nominee for Washington Mutual Bank, FA (none of which has filed a proof of claim) or the Assignment of Mortgage to sustain its claim), the only issue addressed by the parties is whether Wells Fargo has standing to enforce the Note, and, thus, assert Claim No. 1-2.12 This is because, as stated above, Texas follows the majority rule that “[w]hen a mortgage note is transferred, the mortgage or deed of trust is also automatically transferred to the note holder by virtue of the common-law rule that ‘the mortgage follows the note.’ ” Campbell v. Mortg. Elec. Registration Sys., Inc., 2012 WL 1839357, at *4, 2012 Tex.App. LEXIS 4030, at *11-12 (Tex. App. Austin May 18, 2012), quoting J.W.D., Inc. v. Fed. Ins. Co., 806 S.W.2d 327, 329-30 (Tex.App. Austin 1991). See also Kiggundu v. Mortg. Elec. Registration Sys., Inc., 469 Fed.Appx. 330, 332; Richardson v. Ocwen Loan Servicing, LLC, 2014 TJ.S. Dist. LEXIS 177471, at *13 n. 4 (N.D.Tex. Nov. 21, 2014); Nguyen v. Fannie Mae., 958 F.Supp.2d 781, 790 n. *4211 (S.D.Tex.2013); Trimm v. U.S. Bank, N.A., 2014 WL 3535724, at *4-5, 2014 Tex. App. LEXIS 7880, at *14 (Tex.App. Fort Worth July 17, 2014).

Wells Fargo’s right to enforce the Note, and thus its standing to assert Claim No. 1-2, derives from the Note’s status as a negotiable instrument under Texas’ version of the U.C.C. See Tex. Bus. & Com. Code § 3.104(a). The Debtor has not disputed that the Note is negotiable, and the Note in any event satisfies the requirements of a negotiable instrument under Texas law, as it is “an unconditional promise ... to pay a fixed amount of money ... payable to ... order at the time it [was] issued; ... payable ... at a definite time; and does not state any other undertaking or instruction by the person promising or ordering payment to do any act in addition to the payment of money” except as permitted by the statute. Id. See also Farkas v. JP Morgan Chase Bank, 2012 U.S. Dist. LEXIS 190194, at *6-7 (W.D.Tex. June 22, 2012), aff'd, 544 Fed.Appx. 324 (5th Cir.2013), cert. denied, — U.S.-, 134 S.Ct. 628, 187 L.Ed.2d 411 (2013); Steinberg v. Bank of Am., N.A., 498 B.R. 391, 2013 WL 2351797, *3-4, 2013 Bankr.LEXIS 2230, at *12-14 (10th Cir. BAP May 30, 2013).

Under Texas law, a person entitled to enforce a negotiable instrument such as the Note includes “the holder of the instrument,” Tex. Bus. & Com.Code § 3.301(f), and “a holder is ‘the person in possession of a negotiable instrument that is payable either to bearer or to an identified person that is the person in possession.’ ” Nguyen v. Fannie Mae, 958 F.Supp.2d at 787-88 (quoting Tex. Bus. & Com.Code § 1.201(b)(21)(A)).13

Under Texas’ U.C.C.,

(a) If an indorsement is made by the holder of an instrument, whether payable to an identified person or payable to bearer, and the indorsement identifies a person to whom it makes the instrument payable, it is a ‘special indorsement.’ When specially indorsed, an instrument becomes payable to the identified person and may be negotiated14 only by the indorsement of that person ....
(b) If an indorsement is made by the holder of an instrument and it is not a special indorsement, it is a ‘blank indorsement.’ When indorsed in blank, an instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially indorsed.

Tex. Bus. & Com.Code § 3.205. See generally Venegas v. U.S. Bank, Nat’l Ass’n, 2013 WL 1948118, at *3, 2013 U.S. Dist. LEXIS 66000, at *7 (W.D.Tex. May 9, 2013):

Under Texas law, a holder is ‘the person in possession of a negotiable instrument that is payable either to bearer or to an identified person that is the person in possession.’ Tex. Bus. & Com.Code § 1.201(b)(21)(A). ‘A person can become the holder of an instrument when the instrument is issued to that person, or he can become a holder by negotia*43tion.’ Martin v. New Century Mortg. Co., 377 S.W.3d 79, 84 (Tex.App. Houston 2012) (citing Tex. Bus. & Com'.Code § 3.201 cmt. 1). When the instrument is payable to an identified entity, ‘negotiation requires transfer of possession of the instrument and its indorsement by the holder.’ Id. (quoting Tex. Bus. & Com.Code § 3.201(b)). An instrument is payable to bearer when it is indorsed in blank. Tex. Bus. & Com.Code § 3.205(b).

As discussed above, Wells Fargo’s counsel provided the original Note to the Court at the evidentiary hearing, and it was admitted into evidence with the sole caveat that the Debtor disputes the bona tides of ABN Amro’s blank indorsement that appears on it. Trial Tr. at 4-7. Thus, it is uncontroverted that the Note is in Wells Fargo’s possession. In accordance with the foregoing sections of Texas’ U.C.C., therefore, if the blank ABN Amro indorsement is bona fide, Wells Fargo is the holder of the Note, entitled to enforce it. Trimm v. U.S. Bank, N.A., 2014 WL 3535724, at *4, 2014 Tex.App. LEXIS 7880, at *13; Das v. Deutsche Bank Nat’l Trust Co., 2014 WL 1022385, at *3, 2014 Tex. App. LEXIS 2541, at *6 (“An instrument containing a blank endorsement is payable to the bearer and may be negotiated by transfer of possession alone.”). On the other hand, if the indorsement is forged, it is not valid, and — the only other indorsement on the Note being a specific indorsement to ABN Amro — Wells Fargo could not rely on the foregoing statutory provisions to establish that it is the holder of the Note. See In re Pastran, 2010 WL 2773243, at *3, 2010 Bankr.LEXIS 2237, at *10 (“[S]inee [claimant] is in possession of a promissory note endorsed in ‘blank,’ it is, by definition, a ‘holder’ under section 3.201(a). This, of course, assumes that all of the indorsements on the Note are authentic and authorized.”).

Texas’ U.C.C. provides that, although Wells Fargo has the ultimate burden of proof, the indorsements on the Note, including ABN Amro’s all-important blank indorsement by Margaret A. Bezy, Vice President, are presumed to be authentic:

In an action with respect to an instrument, the authenticity of, and authority to make, each signature on the instrument are admitted unless specifically denied in the pleadings. If the validity of a signature is denied in the pleadings, the burden of establishing validity is on the person claiming validity,' but the signature is presumed to be authentic.

Tex. Bus. & Com.Code § 3.308(a) (emphasis added).

Texas’ U.C.C. defines “presumed” as follows: “Whenever this title creates a ‘presumption’ with respect to a fact, or provides that a fact is ‘presumed,’ the trier of fact must find the existence of the fact unless and until evidence is introduced that supports a finding of its nonexistence.” Id. § 1.206(a). In re Pastran, 2010 WL 2773243, at *3, 2010 Bankr.LEX-IS 2237, at *10-11 (“Thus, [the claimant] is not required to prove that the indorse-ments on the Note are valid and authentic unless and until the Debtor overcomes the presumption by putting on evidence that supports a finding that the indorsements on the Note were somehow forged or unauthorized.”).

“The presumption rests upon the fact that in ordinary experience forged or unauthorized signatures are very uncommon, and normally any evidence is within the control of, or more accessible to, the defen*44dant.”15 Official Comment to Tex. Bus. & Com.Code § 3.308 (“OffiCmt.”). The presumption is effectively incorporated into Fed.R.Evid. 902(9), which provides that no extrinsic evidence of authenticity is required to admit “[c]ommercial paper, a signature on it, and related documents, to the extent allowed by general commercial law,” and it is loosely analogous to the rebuttable presumption of the prima facie validity of a properly filed proof of claim under Fed. R. Bankr.P. 3001(f).

While Tex. Bus. & CormCode §§ 3.308(a) and 1.206(a) provide that the presumption of an authentic signature applies “unless and until evidence is introduced that supports a finding of nonexistence,” they do not state the quantum of evidence to overcome the presumption. The Official Comment to § 3.308, however, refers to “some evidence” and to “some sufficient showing of the grounds for the denial before the plaintiff is required to introduce evidence,” and then states, “[t]he defendant’s evidence need not be sufficient to require a directed verdict, but it must be enough to support the denial by permitting a finding in the defendant’s favor.” Off. Cmt. 1 to § 3.308.16 This suggests that the required evidentiary showing to overcome the presumption is similar to that needed to defeat a summary judgment motion: the introduction of sufficient evidence so that a reasonable trier of fact in the context of the dispute could find in the defendant’s favor. See Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 587-88, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986); 11 Moore’s Fed. Prac.3d § 56.22[2] (2014). Because of the general factual context described in the Official Comment, which recognizes that “in ordinary experience forged or unauthorized signatures are very uncommon,” Off. Cmt. 1 to § 3.308, courts have nevertheless required a significant amount of evidence to overcome the presumption. See In re Phillips, 491 B.R. 255, 273 n. 37 (Bankr.D.Nev.2013) (“This evidence was inconclusive at best. Against this background, the court is prepared to believe that it is more likely that [the claimant] negligently failed to copy the Note and First Allonge when it filed its [first] Proof of Claim rather than it forged the First Allonge later on. In short, when both are equally likely, the court picks sloth over venality.”); see also Congress v. U.S. Bank, N.A., 98 So.3d 1165, 1169 (Civ.App. Ala.2012) (referring to requirement of substantial, though not clear and convincing, evidence to rebut the presumption under U.C.C. §§ 3-308(a) and l-206(a),' although directing trial court on remand to apply preponderance-of-the-evidence standard to whether the presumption was overcome).

It is important to keep in mind, however, that if the presumption is overcome, the ultimate burden of proof under Tex. Bus. & Com.Code §§ 3.308(a) and 1.206(a) is on Wells Fargo. See People v. Richetti 302 N.Y. 290, 298, 97 N.E.2d 908 (1951) (“A presumption of regularity exists only until contrary substantial evidence appears .... It forces the opposing party (defendant here) to go forward with proof but, once he does go forward, the presumption is out of the case.”). Thus, in In *45re Phillips, 491 B.R. at 273 n. 37, quoted above, if the presumption had been overcome by a preponderance of the evidence and the burden shifted and forgery and negligence were found to be equally likely, the holder of the note should lose.

What is the Debtor’s evidence that the blank ABN Amro indorsement was forged or unauthorized, and is it sufficient to overcome the presumption under Tex. Bus. & Com.Code §§ 3.308(a) and 1.206(a)?

The Debtor first points out that the version of the Note attached to Wells Fargo’s initial proof of claim, Claim No. 1-1, did not contain the blank ABN Amro in-dorsement. Besides observing that the penalty for filing a false proof of claim, as stated in Official Form 10, can be substantial, the Debtor also observes that, with the exception of the versions of the Note attached, Claim Nos. 1-1 and 1-2 were otherwise identical and included copies of most if not all of the potentially operative documents from Wells Fargo’s files, which, she argues, strongly suggests that Claim No. 1-1 was not merely sloppily prepared but, rather, reflected a thorough review of the flies, thus suggesting a nefarious reason why the form of Note with the blank ABN Amro indorsement was not attached to that proof of claim but was attached to Claim No. 1-2.

Were this the Debtor’s only evidence, the Court might nevertheless hold that she had not overcome the presumption in Tex. Bus. & Com.Code §§ 3.308(a) and 1.206(a). That was the result in In re Phillips, 491 B.R. at 273,17 as well as in In re Hunter, 466 B.R. 439, 449-50 (Bankr.E.D.Tenn. 2012), and In re Wilson, 442 B.R. 10, 15 n. 6 (Bankr.D.Mass.2011). See also Caster-line v. OneWest Bank, F.S.B., 537 Fed. Appx. 314, 318 (5th Cir.2013) (without discussing Tex. Bus. & Com.Code §§ 3.308(a) and 1.206(a), court not bothered by inconsistencies between different forms of note submitted in foreclosure proceeding and in federal court proceeding); Das v. Deutsche Bank Nat’l Trust Co., 2014 WL 1022385, at *2, 2014 Tex.App. LEXIS 2541, at *7-8 (without discussing Tex. Bus. & Com.Code §§ 3.308(a) and 1.206(a), court granted summary judgment declaring lender to be current holder of note although a different version of the note was attached to proof of claim in earlier bankruptcy case). But see Ocwen Loan Servicing, LLC v. Thompson, 2014 WL 51236, at *5, 2014 U.S. Dist. LEXIS 2109, at *14-15 (E.D.Wise. Jan. 7, 2014) (“[H]ere, faced with two materially different versions of the same negotiable instrument (one sans allonge and the other purportedly modified by an allonge), this Court is obliged to concur that application of FRE 902(9) to the latter would be overly mechanistic.”); In re Tarantola, 2010 WL 3022038, at *4-5, 2010 Bankr.LEXIS 2435, at *13 (Bankr.D.Ariz. July 29, 2010) (“[I]n light of [claimant’s] admission that it fabricated, the Allonge, and in the absence of any credible explanation for the difference of the Original from other filed versions of the Note, the Court will not apply the usual evidentiary presumptions to the validity of the Endorsements.”).

In addition, however, the Debtor relies on the Assignment of Mortgage from MERS, “as nominee for Washington Mutual Bank, FA” having been executed by Mr. Kennerty, an officer of Wells Fargo (the assignee), on behalf of the assignor. Even more tellingly, it appears clear from the date of the Assignment — only three days *46before the date of Claim No. 1-1 — as well as Mr. Kennerty’s deposition testimony, that the Assignment was prepared by Wells Fargo’s then counsel to “improve” the record supporting Wells Fargo’s right to file a secured claim, similar to the “improvement” of the record in In re Tarantola, cited above, on which the court relied, along with the two different versions of the note at issue there, to find that the presumption of authenticity was rebutted. 2010 WL 3022038, at *4-5,2010 Bankr.LEXIS 2435, at *12-13.18 (The timing of the filing of Claim No. 1-2 only after the Debtor pointed out the difficulty of Wells Fargo’s ability to enforce the form of Note attached to Claim No. 1-1 also distinguishes this matter from the facts in In re Phillips, as discussed in note 17 above.)

It appears from Mr. Kennerty’s deposition transcript, although his testimony on this point was at times quite evasive, that during the period in question in 2010 he signed on average between 50 and 150 original documents a day in connection with Wells Fargo’s administration and enforcement of defaulted loans. Deposition Transcript, dated October 15, 2012, of Herman John Kennerty (“Dep.Tr.”) at 89-92. This was part of his duties as the Wells Fargo manager in charge of “default documents.” Id. at 44. In other words, on a daily basis Mr. Kennerty and his team, members of which he also testified signed a like number of documents each day, id., processed a large volume of loan documents for enforcement with very little thought about what they were doing. It is not clear that Mr. Kennerty fully understood the legal consequences of signing these documents; for example, he testified when shown the Assignment of Mortgage that he executed it not on behalf of the assigning party but, rather, on behalf of the party “in getting the assignment,” although he also testified that “I’m — I’m not an attorney, but the way I understand this document, it was assigning the mortgage, taking it out of MERS’ name and putting into Wells Fargo Bank’s name.” Id. at 93-4. It is clear, however, that he pretty much signed whatever outside counsel working on the default put in front of him and that these documents often included assignments, including the Assignment of Mortgage, drafted by Wells Fargo’s outside enforcement counsel to fill in missing gaps in the record.

Thus, in describing the work of his “assignment team” Mr. Kennerty stated, “[I]f there was not an assignment in there [that is, in Wells Fargo’s loan file] then they would — excuse me, they would advise the attorney that we did not have it, that they would need to draft the — the appropriate assignment.” Id. at 116. See also id. at 76 (“[I]f the assignment needed to be created they would have advised the attorney, the requesting attorney to — that we did not have the assignment in the collateral file, then they needed to draw up the appropriate document.”); id. at 121 (“Once it [that is, the collateral file] was received then they would check to see if it was something that could be used or not used; and, if it’s something that was in the file, but couldn’t be used then they would advise the requesting attorney to go ahead and draft the actual document.”).

Because Wells Fargo does not rely on the Assignment of Mortgage to prove its claim, the foregoing evidence is helpful to *47the Debtor only indirectly, insofar as it goes to show that the blank indorsement, upon which Wells Fargo is relying, was forged. Nevertheless it does show a general willingness and practice on Wells Fargo’s part to create documentary evidence, after-the-fact, when enforcing its claims, WHICH IS EXTRAORDINARY.19

Moreover, Mr. Kennerty’s testimony does not stop at describing manufactured mortgage assignments. He also testified that his “assignment team’s” duties were not limited to processing assignments, including, when determined necessary, creating them; in addition, the “assignment team” included people tasked with endorsing notes. Id. at 136. His testimony on this issue is critical and will be quoted at length:

Q. Okay. Did your department endorse notes?
A. Yes.
Q. Okay. And how was it that your department would come to endorse notes?
A. I don’t recall the specific process, but to the best of my recollection there’s usually a — in—usually a — blank endorsement on — on the notes and there would — -and then based on that they would complete the endorsement.
Q. So when you say they would complete the endorsement, who is they?
A. I’m sorry. There was a — there— there were some processors that would perform that task.
Q. Okay. When you say complete the endorsement, what do you mean by that?
A. They would execute a note endorsement, a new note endorsement if there was a blank one on there.
Q. And they would do that with the original note from the collateral file?
A. To the best of my recollection, yes.
Q. Okay. And at whose request would the processors perform that function?
A. Again, to the best of my recollection, it would be done at the — either the foreclosure attorney’s requést or the bankruptcy attorney’s request.

Id. at 129-31.

Mr. Kennerty then testified about the process for receiving such requests from outside enforcement attorneys and how one or two people in his department had *48the job of endorsing notes. Id. at 131-32. When questioned about how often such requests were made, whether on a daily basis or on rare occasions, Mr. Kennerty replied, “To the best of my recollection, it was on a regular basis.” Id. at 133. He also testified about the information system or systems at Wells Fargo where such requests might be made and maintained.20 Id. at 133-34.

He then testified as follows:

Q. And the actual procedure for endorsing an original note, if you could just walk me through that process. What would the processor do?
A. To the best of my recollection, they would — the request would come in. Again, we would check to see if we had the collateral file. If we — if we had it and depending on the status of the — of the loan itself, if we had the note then we could check to see, you know, what was actually on the note to see what needed to be done. If we did not have the collateral file then they would work — that processor would work with the collateral file ordering team to reach out with the appropriate attorney or, I’m sorry, the appropriate custodian to obtain the collateral file. And then they would look to — once the file came in they would look to ensure that the original note was in there and check to see if there was any endorsement on the back of the note.
Q. Okay. And if there wasn’t how would they go about — how would the processor go about endorsing the note ?
A. I don’t recall specifically how they completed that particular task.
Q. Was it a rubber stamp? Was it somebody signing? How was it?
A. To the best of my recollection, a stamp was involved but then it had to be signed.
Q. Okay. And if an endorsement was coming from an entity that no longer existed how would it be signed?
A. I do not recall.

Id. at 135-36 (emphasis added).

Later in his deposition, Mr. Kennerty was shown the two forms of the Note attached to Claim Nos. 1-1 and No. 1-2, respectively, and testified that he did not know how or when the indorsements were placed on them. Id. at 142-44. He did have this to say, however:

Q. Now, if any one of these endorsements were a rubber stamp and produced by your department would there be a record of that somewhere?
Mr. Cromwell: Objection; misstates his testimony.
Witness. I — the term rubber stamp is a — not accurate because although the — a stamp to produce the ‘pay to order of was used, the term to me, use of a rubber stamp, means it was signed, there was a signature on the — on the stamp itself and that — to my recollection, that was not the case.

Id. at 143-44. Mr. Kennerty said nothing more that was relevant to the issue of whether Wells Fargo forged the blank ABN Amro indorsement, with the exception of stating that “I am not familiar with Margaret Bezy,” id. at 143, who has not been identified as ever having been an employee of Wells Fargo and presumably was an employee of ABN Amro.

I conclude that the foregoing evidence cumulatively shifts the burden to Wells Fargo under Tex. Bus. & Com.Code §§ 3.308(a) and l-206(a) to show the authenticity of the blank ABN Amro indorsement to establish its status as a holder of *49the Note under Tex. Bus. & Com.Code §§ 3.301(i) and 3.201(a). It constitutes substantial evidence that Wells Fargo’s administrative group responsible for the documentary aspects of enforcing defaulted loan documents created new mortgage assignments and forged indorsements when it was determined by outside counsel that they were required to enforc

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