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MINDD - ASSOCIAÇÃO NACIONAL DE DEFESA DAS VITIMAS DOS FALSOS CONDOMINIOS - 13.06.2008 A 13.06.2025- 18 ANOS DE GRANDES VITORIAS FALSE CONDOMINIUMS´s VICTIMS Community- A non-profit organisation focusing on Human Rights issues around the world, with particular focus on BRAZIL - DESDE 2008 AJUDANDO A DEFENDER A DEMOCRACIA E DIREITOS HUMANOS NO BRASIL - email : mindd.defesa.de.direitos@gmail.com
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sexta-feira, 3 de abril de 2026
GLORIA A DEUS ! MILAGRES ACONTECERAM ESTA SEMANA : RECEBI MAIS UMA BOA NOTICIA AO FINAL DA SANTA MISSA COM O PADRE MARCELO ROSSI - SEXTA FEIRA DA PAIXÃO GLORY TO GOD! MIRACLES HAPPENED AFTER THE HOLY MASS WITH FATHER MARCELO ROSSI - GOOD FRIDAY
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Uma Vitória da Verdade na Sexta-Feira Santa : A Proteção Divina e a Luta Incessante: A Justiça de Deus sobre o Arbítrio dos Homens :A Record for the People: Legal Presentations and the Question of Adjudication in Washington State Courts” By Scott Erik Stafne, attorney, WSBA # 6964
DEUS OUVIU O NOSSO CLAMOR, ALELUIA !
ENTROU COM PROVIDÊNCIA
A AUDIÊNCIA DE JULGAMENTO SUMÁRIO AGENDADA PARA HOJE AS 09 HS - PIERCE COUNTY, WS, USA - (13 HS BRASÍLIA) EM AFRONTA À SAGRADA PAIXÃO DE NOSSO SENHOR E SALVADOR JESUS CRISTO FOI CANCELADA, da APÓS a petição de SUSPEIÇÃO do JUIZ THOMAZ MATTHEW -
“A Record for the People: Legal Presentations and the Question of Adjudication in Washington State Courts” By Scott Erik Stafne, attorney, WSBA # 6964
By Scott E Stafne
Conforme solicitado, aqui está a transcrição literal da petição de impedimento apresentada por Scott Stafne:
“Um Registro para o Povo: Peças Jurídicas e a Questão da Adjudicação nos Tribunais do Estado de Washington”
Por Scott Erik Stafne, advogado, WSBA nº 6964
INDICE
* Página 1: Notice of Appearance –
* Página 5: Affidavit of Prejudice and Notice of Disqualification –
* Página 8: Objection to Nominal Defendant Status –
* Página 13:
* Página 17: Request for Reasonable Accommodation –
* Página 20: Declaration for GR33 ADA Accommodation –
* Página 23: Response to Deutsche Bank’s Motion for Summary Judgment
* Página 25 em diante: Lista de 32 Provas (Exhibits) fundamentais, incluindo:
* Exhibit 18 & 29: Declarações do Dr. James Kelley (Engenheiro de Computação) provando que as notas são reproduções digitais/forjadas.[2, 1]
* Exhibit 19: Declaração de William Paatalo (Investigador) sobre a destruição de notas originais pela indústria financeira.[1]
* Exhibit 32: Declaração de Jess Almanza negando ter assinado os endossos alegados pelo banco.[1]
Transcription: Affidavit of Prejudice (Pierce County Superior Court)
Título: A Proteção Divina e a Luta Incessante: A Justiça de Deus sobre o Arbítrio dos Homens
* Violação do Direito a um Tribunal Imparcial:
O fiduciário (MTC/QLS) é pago pelo banco para atuar como "juiz" substituto, o que fere o princípio nemo judex in causa sua (ninguém pode ser juiz em causa própria).[1]
* Crueldade e Discriminação:
quarta-feira, 1 de abril de 2026
THE TRIBUNAL OF PROFANATION: LAST-MINUTE REASSIGNMENT, PENDING RECUSAL, AND THE ATTEMPTED SUMMARY JUDGMENT ON GOOD FRIDAY IN THE WHITE CASENOW THERE IS A NEW PROBLEM: THE REASSIGNED JUDGE AND THE ABSENCE OF A RESPONSE: 23-2-11864-8 - CHURCH OF THE GARDENS VS. DEUTSCHE BANK (QUALITY LOAN SERVICES CORP OF WASHINGTON)
THE TRIBUNAL OF PROFANATION: LAST-MINUTE REASSIGNMENT, PENDING RECUSAL, AND THE ATTEMPTED SUMMARY JUDGMENT ON GOOD FRIDAY IN THE WHITE CASE
The case of Church of the Gardens and Alvin White v. Deutsche Bank National Trust Company et al. can no longer be described as an ordinary mortgage dispute. What is exposed in the records is something more severe: a succession of procedural maneuvers, undecided constitutional questions, technical evidence challenging the authenticity of the documents, and, now, a summary judgment hearing scheduled for Good Friday, followed by a last-minute reassignment to a judge whose impartiality was immediately challenged.
THE BANGALORE PRINCIPLES OF JUDICIAL CONDUCT [ CLICK HERE ]
The central question remains simple and devastating:
How can a court grant summary judgment in favor of a bank when no court has ever validly and previously decided whether that bank had the legal right to enforce the promissory note?
This question remains unanswered.
And that is exactly why the attempt to close the case by summary judgment now is so grave.
I. WHAT HAPPENED NOW
Deutsche Bank requested a summary judgment. The hearing was scheduled for Friday, April 3, 2026, at 9:00 a.m., on Good Friday, in a case involving a religious entity, The Church of the Gardens, and serious structural allegations regarding standing to collect, jurisdiction, trustee neutrality, and the authenticity of the instruments.
Scott E. Stafne filed an opposition to the summary judgment.
Then, at the last minute, the case was removed from the previously assigned judge and reassigned to Judge Matthew H. Thomas, the same judge linked to the Morton case, in which Scott was previously sanctioned. In light of this, Scott filed a challenge for partiality/suspicion or recusal on Tuesday.
By Wednesday, however, there was no definitive answer.
Worse: while the issue of the judge's replacement remained unresolved, the court's administrative machine continued operating as if Friday's hearing would proceed normally.
In the exchanged emails, the judicial assistant informed that the request for the assignment of a new judge had been sent to administration, but that there was still no notification of a new judge. In parallel, there was administrative communication about two boxes of materials for the motion scheduled for Friday, revealing that the hearing's logistics kept moving, despite the pending challenge against the judge.
This is not an irrelevant bureaucratic detail.
This means, in practical terms, that the parties were left under the threat of a potentially dispositive hearing without knowing, until the last minute, who would judge the case and whether the impartiality challenge would be considered before the merits.
This is procedural pressure. This is concrete prejudice to the defense. And this is incompatible with the judicial neutrality that due process requires.
II. THE DATE IS NOT NEUTRAL
The hearing was scheduled for Good Friday, one of the holiest days of the Christian calendar.
For millions of Christians, this is a day of prayer, fasting, mourning, reflection, and remembrance of the unjust condemnation of Jesus Christ under institutional and political pressure.
When a court holds, on such a date, a summary judgment hearing against a Christian church and its procedural allies, the issue is not mere cultural sensitivity. In the concrete context of the case, this imposes an objective burden on religious exercise and aggravates the appearance of procedural abuse.
This is not to say that any procedural act on Good Friday is automatically unconstitutional. It is to recognize that, in this specific context, maintaining this hearing on this date, without demonstrated urgent necessity, against a church and in a case fraught with unresolved procedural defects, deepens the appearance of coercion, institutional disrespect, and undue compression of the defense's time.
III. THE CENTRAL QUESTION WAS NEVER ADJUDICATED
The core of the case is not peripheral. It is the heart of the controversy:
Who, if anyone, had the right to enforce Alvin White's promissory notes under Washington law, especially RCW 62A.3-301?
The plaintiffs have repeatedly maintained that no court has validly adjudicated this question before the trustee’s sales proceeded. This point appears in a structured manner in the response to the summary judgment motion after the case returned to state court:
https://www.academia.edu/165289536/Pierce_County_Washington_Superior_Court_upon_Remand_from_US_District_Court_Church_of_the_Gardens_and_White_v_Deutsche_Bank_National_Trust_Company_et_al_Church_of_the_Gardens_and_property_owner_Whites_response_to_Deutsche_Banks_motion_for_summary_judgment?source=swp_share
The thesis is straightforward: the case was removed to federal court before the central questions were adjudicated; the plaintiffs challenged jurisdiction and standing; and, even so, property acts moved forward without a court having decided whether Deutsche Bank was or was not the "person entitled to enforce" the note. This framing also appears in the material “Truth, Authority, and Adjudication”, which stems precisely from the tensions between Article III, standing, trustee liability, and summary judgment practice.
If this is true — and the records say that this question was never properly decided — then the attempt to obtain summary judgment now does not solve the problem. It only attempts to cover it up.
IV. THE JURISDICTIONAL PING-PONG
When the plaintiffs demanded that the bank demonstrate it was the party legally authorized to enforce the debt, the litigation was removed to the federal sphere.
These materials document the federal controversy, including the clashes over standing, jurisdiction, and post-judgment:
Deutsche Bank's Opposition: https://www.academia.edu/144230264/United_States_District_Court_for_Western_Washington_Church_of_the_Gardens_and_Alvin_White_vs_Quality_Loan_Services_Corporation_of_Washington_Deutsche_Banks_opposition_to_Plaintiffs_Motion_for_Post_Judgment_Relief
Plaintiffs' Reply: https://www.academia.edu/144308990/US_District_Court_for_Western_Washington_Church_of_the_Gardens_and_Alvin_White_vs_Quality_Loan_Services_Corporation_of_Washington_Plaintiffs_Church_of_the_Gardens_and_Alvin_White_Reply_to_Deutsche_Banks_opposition_to_Plaintiffs_Motion_for_Post_Judgment_Relief
Material related to the federal process: https://www.academia.edu/144308750/UNITED_STATES_DISTRICT_COURT_WESTERN_DISTRICT_OF_WASHINGTON_AT_TACOMA
The structural critique is this: if the federal court did not validly establish standing and subject-matter jurisdiction, then it could not exercise Article III judicial power to affect real property rights. The document “Truth, Authority, and Adjudication” itself develops this argument by discussing Sprint and the need to verify whether the type of plaintiff and the type of claim historically fall within the scope of federal judicial power.
After almost two years in the federal sphere, the case returned to state court. And now the bank tries to accelerate a summary judgment as if the previous structural defect had magically disappeared.
It did not disappear.
V. WHAT IS AT STAKE IS NOT “JUST” A SUMMARY JUDGMENT
Summary judgment is only admissible when there is no genuine controversy over material facts.
But here the material facts are vast and central:
* who had the right to enforce the note;
* whether the chain of transfers is valid;
* whether the purported beneficiary had authority;
* whether the trustee acted with neutrality or just followed orders;
* whether the presented documents are authentic;
* whether or not there was valid adjudication before the loss of property rights.
No honest court can state "there is no genuine controversy over material facts" when the essential question of the right of enforcement was never decided and when the records themselves present serious technical challenges to documentary authenticity.
VI. THE TECHNICAL EVIDENCE IS NOT RHETORIC
This case is not sustained solely on moral outrage or abstract argumentation. There is technical material.
The memorandum by William J. Paatalo, attached to this conversation, demonstrates a structural problem in mortgage securitization: the fragmentation between economic interest, fiduciary title, and operational authority can make it impossible to identify a single party with the full legal authority of a traditional creditor. The point of the memorandum is clear: the question is not whether a debt once existed; the question is whether any currently identified party can be verified as the party with the legal authority and capacity to act as a creditor.
Furthermore, within the White case's own set of filings appears the allegation that Jeff/Jess Almanza declared not to have signed the endorsements in blank and that William Paatalo was retained as an expert to analyze the documentary structure and the banking narrative surrounding the notes, the assignments, and the purported enforcement chain. This is reflected in the material filed in the state sale restraint proceeding and its exhibits, including references to Paatalo's report and Almanza's declaration.
If the central documents are challenged by technical evidence and testimonies related to authenticity, summary judgment ceases to be a legitimate shortcut and becomes an attempt to avoid factfinding.
VII. THE EVICTION PROCESS ITSELF REVEALS THE MANEUVER
Another important filing is the “Answer, Affirmative Defenses, Counterclaims, and Cross Claims” presented in the unlawful detainer/eviction process. It documents the thesis that the possession claimed by Deutsche Bank derives entirely from trustee’s sales and procedures whose validity depends on prior acts challenged for lack of standing, lack of valid jurisdiction, and violation of due process. The filing maintains that the trustee acted under a structural conflict incompatible with Tumey, that the state foreclosure procedures were used to deprive White of property without constitutionally sufficient adjudication, and that the right to possession claimed by the bank derives from structurally defective federal and state processes.
Even more grave: this same filing was submitted in February 2026 and, according to the material's own abstract, had not been filed until two days later. Its content is extremely dangerous to the bank's narrative because it transforms the case from "mere collection/possession" into an open discussion about Article III, void judgment, due process, trustee neutrality, and § 1983.
In other words: when the full defense enters, the case stops being a banal foreclosure and begins to expose an architecture of property deprivation without sufficient prior adjudication.
VIII. NOW THERE IS A NEW PROBLEM: THE REASSIGNED JUDGE AND THE ABSENCE OF A RESPONSE
All this would already be grave on its own. But the picture has worsened.
The hearing that was previously before Michael E. Schwartz was reassigned, at the last minute, to Matthew H. Thomas. Scott informed that he would present a motion to disqualify him for partiality and, subsidiarily, would invoke the Church's right to disqualification under another rule. According to the most recent communication from the judicial assistant, the request for the assignment of a new judge was sent to administration, but, up to that moment, there was still no notification of the new assignment.
This generates an unacceptable situation:
* there is a potentially dispositive hearing;
* the assigned judge was challenged;
* the administration acknowledges that the request was forwarded;
* and, even so, there is no decision resolving the issue before the hearing.
No substantive summary judgment hearing should proceed while a timely challenge to the judge's impartiality remains unresolved.
Proceeding in this manner transforms the uncertainty about judicial neutrality into an instrument of pressure.
IX. THIS IS NO LONGER JUST A FORECLOSURE CASE
The White case is no longer limited to five properties or a disputed debt.
It is about whether the courts will permit the deprivation of assets:
* without prior adjudication of the right of enforcement;
* despite technical evidence questioning the authenticity of the documents;
* after a federal journey where standing and jurisdiction were challenged;
* through a request for summary judgment on a religiously burdensome date;
* and now under a framework of last-minute reassignment and a recusal/suspicion still pending decision.
If this is permitted, the problem ceases to be merely legal.
It becomes historical, institutional, and moral.
Justice is not profaned only by false evidence.
It is also profaned when courts allow unadjudicated structural issues to be buried under aggressive procedural calendars, compression of defense time, deliberately maintained uncertainty about the competent judge, and summary decisions without the necessary factfinding to support them.
X. ESSENTIAL LINKS FOR READING THE CASE FILES AND RELATED MATERIALS
Response to the motion for summary judgment in state court: https://www.academia.edu/165289536/Pierce_County_Washington_Superior_Court_upon_Remand_from_US_District_Court_Church_of_the_Gardens_and_White_v_Deutsche_Bank_National_Trust_Company_et_al_Church_of_the_Gardens_and_property_owner_Whites_response_to_Deutsche_Banks_motion_for_summary_judgment?source=swp_share
Petition for discretionary review in the Washington Supreme Court: https://www.academia.edu/164466372/Washington_Supreme_Court_Church_and_White_v_Clear_Recon_Corp_v_Deutsche_Bank_Petition_for_Discretionary_Review?source=swp_share
Deutsche Bank's opposition in the federal post-judgment: https://www.academia.edu/144230264/United_States_District_Court_for_Western_Washington_Church_of_the_Gardens_and_Alvin_White_vs_Quality_Loan_Services_Corporation_of_Washington_Deutsche_Banks_opposition_to_Plaintiffs_Motion_for_Post_Judgment_Relief
Plaintiffs' reply in the federal post-judgment: https://www.academia.edu/144308990/US_District_Court_for_Western_Washington_Church_of_the_Gardens_and_Alvin_White_vs_Quality_Loan_Services_Corporation_of_Washington_Plaintiffs_Church_of_the_Gardens_and_Alvin_White_Reply_to_Deutsche_Banks_opposition_to_Plaintiffs_Motion_for_Post_Judgment_Relief
Text related to the federal process: https://www.academia.edu/144308750/UNITED_STATES_DISTRICT_COURT_WESTERN_DISTRICT_OF_WASHINGTON_AT_TACOMA
Filing in the eviction/unlawful detainer process: https://www.academia.edu/164798332/Pierce_County_Washington_Superior_Court_Deutsche_Bank_National_Trust_Company_as_Trustee_in_Trust_for_Registered_Holders_of_Long_Beach_Mortgage_Trust_2006_5_Asset_Backed_Certificates_Series_2006_5_v_Alvin_White_et_al_Whites_Answer_Affirmative_Defenses_Counterclaims_and_Cross_Claims?source=swp_share
William J. Paatalo's memorandum: https://www.academia.edu/165393558/William_J_Paatalo_Private_Investigator_OR_PSID_49411_LEGAL_MEMORANDUM_Re_Structural_Creditor_Identification_Problems_in_Securitized_Mortgage_Transactions?source=swp_share
“Truth, Authority, and Adjudication”: https://www.academia.edu/165428546/Truth_Authority_and_Adjudication_A_Holy_Week_Dialogue_on_Law_Systems_and_Discernment?source=swp_share
XI. CONCLUSION
The truth is in the records.
And the question that now hangs over the Pierce County Superior Court is not small:
will the court first resolve the issue of judicial impartiality, address the lack of prior decision on the right to enforce the note, seriously consider the technical evidence, and respect due process?
Or will it allow a dispositive outcome to be hastily pursued, on Good Friday, under the shadow of an unresolved recusal and fundamental questions that were never adjudicated?
We will be watching.
The text has been translated literally while maintaining accurate legal terminology in English. If you would like me to proceed with adapting this into the shorter, more explosive format for Blogger as you suggested, just let me know!
Brazil is a respondent in more than 15 cases adjudicated by the Inter-American Court of Human Rights.
Brazil is a respondent in more than 15 cases adjudicated by the Inter-American Court of Human Rights.
Inter-American Court of Human Rights – Cases Against Brazil
Key Judgments and Official Links
Below is a precise and legally relevant list of major cases decided against Brazil by the Inter-American Court of Human Rights, with official links to the judgments.
1. Case of Ximenes Lopes v. Brazil
Subject: Violation of the rights of a person with a mental disorder in a psychiatric institution.
Milestone: First judgment against Brazil before the Court.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_149_ing.pdf
2. Case of Garibaldi v. Brazil
Subject: Killing in the context of a rural land conflict and failure to investigate.
Focus: The State’s duty to investigate rural violence.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_203_ing.pdf
3. Case of Escher et al. v. Brazil
Subject: Illegal telephone interceptions.
Impact: Protection of privacy and due process.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_200_ing.pdf
4. Case of Gomes Lund et al. (“Guerrilha do Araguaia”) v. Brazil
Subject: Enforced disappearances during the dictatorship.
Impact: Incompatibility of the Amnesty Law with the American Convention.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_219_ing.pdf
5. Case of Workers of the Hacienda Brasil Verde v. Brazil
Subject: Contemporary slave labor.
Milestone: Recognition of modern slavery as a human rights violation.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_318_ing.pdf
6. Case of Favela Nova Brasília v. Brazil
Subject: Extrajudicial executions and police violence.
Impact: Duty to investigate deaths caused by State agents.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_333_ing.pdf
7. Case of Herzog et al. v. Brazil
Subject: Torture and death of a journalist during the dictatorship.
Impact: Non-applicability of statutes of limitation to crimes against humanity.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_353_ing.pdf
8. Case of Nogueira de Carvalho et al. v. Brazil
Subject: Failure to protect a human rights defender.
Result: No full attribution of international responsibility, but still a relevant landmark case.
Official English PDF:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_161_ing.pdf
9. Case of Leite de Souza y otros v. Brazil
Subject: Enforced disappearance.
Official status on the Court’s site: judgment listed on the official page, but marked “Only in Spanish.”
Official Court judgments page:
https://www.corteidh.or.cr/casos_sentencias.cfm?lang=em
10. Case of Tavares Pereira y otros v. Brazil
Subject: Death and injuries in the context of State repression of a land-reform march, plus judicial protection issues. The official judgment itself states that the case concerns the killing of Antônio Tavares Pereira, injuries to rural workers of the MST, and the State’s response.
Official Court judgments page:
https://www.corteidh.or.cr/casos_sentencias.cfm?lang=em
Official direct PDF found:
https://www.corteidh.or.cr/docs/casos/articulos/seriec_507_esp.pdf
Important technical note
The official Court site confirms both names as official case titles: Leite de Souza y otros v. Brazil and Tavares Pereira y otros v. Brazil. For Leite de Souza, the official page indicates Spanish only. For Tavares Pereira, I found the official direct PDF in Spanish and verified from the judgment itself that it is the case concerning Antônio Tavares Pereira and the repression of the agrarian reform march in Paraná.
If you want, I can now turn this into a clean publication-ready English list with uniform formatting and no notes.
Justice without proof is not justice. It is only power without truth. : William J. Paatalo – Private Investigator – OR PSID# 49411 -- LEGAL MEMORANDUM Re: Structural Creditor-Identification Problems in Securitized Mortgage Transactions By Scott E Stafne
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ALVIN WHITE V DEUTSCHE BANK
William J. Paatalo – Private Investigator – OR PSID# 49411 -- LEGAL MEMORANDUM Re: Structural Creditor-Identification Problems in Securitized Mortgage Transactions
By Scott E Stafne
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Constitutional Law,
International Law,
Courts,
Property Law,
Legal Theory,
International Human Rights Law,
Property,
Truth,
Political Corruption,
War Crimes,
Adjudication,
Courts and Elites (History),
Court history,
Mortgage Foreclosure,
Corruption,
Constitutional Courts,
Mortgages,
Subprime Mortgage Crisis,
Subprime crisis,
Human Rights and Corruption
ISSUE PRESENTED:
Whether modern residential mortgage securitization separates economic interests, fiduciary title, and servicing authority in a manner that can make it impossible to identify and verify a single party with the full legal authority and capacity of a traditional mortgage creditor, particularly when that authority is tested through administrative verification demands and later examined in quiet title proceedings.






