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Todd Wetzelberger c/o P.O. Box 24702
Baltimore, Maryland 21220
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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Todd Wetzelberger
Petitioner, v.
M&T BANK CORPORATION, et al.,
Respondents,
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COMES NOW, Todd Wetzelberger, Petitioner (hereinafter Wetzelberger), by special and restrictive appearance; without waiving any rights or remedies, substantive or procedural including jurisdictional defects; without waiving subject matter, in rem, or in personam jurisdiction; does not consent to the jurisdiction of this court by general appearance or by contract; for purposes of appeal, and collateral attack, and moves the court to enter an order remanding the instant case that was erroneously removed to federal court, to The Supreme Court of The State of New York, County of Kings, for lack of jurisdiction per 28 U.S.C. § 1332(a), and to enter an award of costs and fees in favor of Petitioner.
1.The grounds for Petitioner’s motion are as follows:
2. S. Robert Schrager, Esq., with no first hand knowledge, or credibility as a witness to testify as to any facts, uttered unsubstantiated opinions with no foundation, and selectively omitted substantive facts, either out of carelessness or in an attempt to mislead the court into believing that removal is proper, that Wetzelberger is a deadbeat who “defaulted”, etc.
3.This is the same tired boring “argument” that attorneys in Maryland, and now New York, have repeatedly attempted to assert on paper in the instant case and related cases. However,
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Case Number 12 Civ. 3685 (BMC)
PETITIONER’S MOTION TO
REMAND TO STATE COURT
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Wetzelberger’s testimony and respondent Thomas P. Dore’s (Dore) testimony (admitting he has no credibility to authenticate any documents) are the only statements in the record made under oath.
4.Every time Wetzelberger has attempted to get an oral hearing scheduled for the past 2 years, so that said attorneys could make their written statements under oath and penalty of perjury, Wetzelberger has been repeatedly obstructed to shield said attorneys.
5.A reasonable person can make their own inference from that un-rebutted fact. The term
“paper tiger” has direct applicability to the instant case. The following is a short list of facts either purposely, or carelessly omitted.
6.M&T Bank Corporation, IRS EIN # 16-0968385 (hereinafter MTB) is not incorrectly named as evidenced by MTB’s own SEC public record filing. The entity named as respondent was very specifically chosen from among several entities (including M&T Bank, Manufacturers and Traders Trust Company, et al.) within the MTB umbrella of companies and subsidiaries.
Washington, D.C. 20549

For the quarterly period ended March 31, 2012 or

Commission File Number 1-9861
(Exact name of registrant as specified in its charter)
New York
(State or other jurisdiction of incorporation or organization)
One M & T Plaza
Buffalo, New York
(Address of principal executive offices)
(716) 842-5445
(Registrant’s telephone number, including area code)
16-0968385
(I.R.S. Employer
Identification No.)
14203
(Zip Code)
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7.Wetzelberger, has sought validation, authentication, and substantiation of the purported
“account” allegedly held by M&T Bank Corporation (hereinafter MTB) since 22 June 2009, over 1035 days ago . (Pet. Ex 1 to Petition for pre-suit discovery at ¶ 11).
8.Knowing MTB’s purported claim was a sham and a fraud, and knowing that MTB never suffered any injury, due to an alleged “default”, Wetzelberger further exposed MTB’s attempt to coerce a thing of value from Wetzelberger by tendering legal tender funds with a neutral 3 rd party escrow agent to settle the purported “account”, and force the return of Wetzelberger’s personal property, the original, unaltered, genuine un-bifurcated wet ink note and original, unaltered, genuine, un-bifurcated deed of trust (DOT).
9.MTB, in flagrant violation of both state and federally mandated laws, failed and refused to comply with its duty to validate, substantiate, and authenticate the purported claim. The fact is
MTB cannot produce any admissible evidence to support MTB’s purported claim.
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Neither Dore nor MTB have proffered any admissible, authenticated evidence of purported “default”, purported “injury” to Dore or MTB, or any amount due and owing to MTB, despite repeated attempts by Wetzelberger to force MTB and Dore to prove their purported claim.
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One only has to look at the evidence entered into the record by Wetzelberger, specifically MTB’s own 1099a that states clearly in Box 5 “Was borrower personally liable for repayment of the debt? NO” (Pet. Ex. 2 to pre-suit discovery at ¶ 17).
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One would look like a fool to attempt to dance around the 1099a filed with the IRS when combined with MTB’s own 2007 10k Annual Report where MTB admits not listing special purpose vehicles (SPV) on their balance sheet (Pet. Pre-suit discovery at ¶ 31, p. 117 of 2007
10k)
13.
In February 2010, Wetzelberger personally served evidence of MTB’s fraud upon
Wetzelberger to the Baltimore, Md. Office of the FBI and spoke at length with the White Collar
Crimes Supervisor at the time John Coliano. Agent Coliano believed the issue was a civil matter at the time, but nonetheless suggested Wetzelberger continue to gather any/all evidence.
Wetzelberger has been doing just that for the past 2 ½ years.
14.
On 13 January 2010, infamous fraudclosure mill attorney, as purported substitute trustee, Thomas P. Dore Esq., who has gotten caught filing hundreds of fraudulent cases in
Maryland courts, filed a fraudclosure case against Wetzelberger, despite the fact that validation,
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Maryland, being a quasi-judicial foreclosure state, only requires the docketing of a purported “complaint” alleging a purported “default” and purported “injury” before the property is allegedly “sold” outside of judicial review. There is no other requirement to produce admissible evidence that the Plaintiff has standing or that conditions precedent were met to “sell” the property.
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Dore and respondents Shannon Menapace, Esq., and Gerard F. Miles Jr. Esq., (self appointed “substitute” trustees with robo-signed documents), have a pattern and practice of repeating this scam over and over.
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The fact that 18 notaries that notarized documents on “Dore” cases have hid behind the
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amendment privilege to not incriminate themselves, and the fact that several other notaries have had their notary commissions stripped by the Md. Secretary of State for fraudulent notarizations on “Dore” cases, would lead a reasonable person and trier of fact (not suffering under mental disability) to question the practices of a known fraudclosure mill and demand strict proof.
18.
Dore himself admitted in the 11 August 2010 hearing testimony (Pet. Ex A to Motion to Remand) that he has no credibility as a witness, has no first hand knowledge of any purported facts, cannot authenticate any documents, is not the document custodian, and is not an expert witness.
19.
Despite the failure of MTB and Dore to produce any admissible evidence, the Maryland
“just-us” system has attempted to obstruct Wetzelberger from ever getting Dore back into a courtroom, and to acquire any of the documents requested over 3 years ago.
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To this day Wetzelberger has not gotten access to question 1 witness, other than getting lucky enough to partially examine Dore, when Dore surprisingly offered to be sworn in with no notice to Wetzelberger at the 11 August 2010 hearing.
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Despite the fact that the Md. Court of Appeals adopted Rule 14-207.1 (Show Cause
Hearing) in 2010, (Pet. for pre-suit discovery at ¶¶ 43-44) in response to the rampant filing of fraudulent documents in fraudclosure cases, Wetzelberger was repeatedly denied a hearing per that rule.
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In fact, ever since Dore’s admissions in the 11 August 2010 hearing, Wetzelberger has been obstructed from ever getting back into a courtroom to personally examine witnesses under oath, despite repeated requests for a hearing per Md. Rule 2-311(f).
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Said case is currently on interlocutory appeal pending a decision on Wetzelberger’s
Petition for Writ of Certoriari in the Md. Court of Appeals, and Petition for Writ of Certoriari to the U.S. Supreme Court Rule 13, if necessary.
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Wetzelberger prematurely filed a counterclaim against Dore, MTB, and other coconspirators, while said case was pending appeal. Dore himself stated the Circuit Court did not have jurisdiction to hear Wetzelberger’s counter-claim (Pet. Ex B to Motion to Remand) and
Wetzelberger agreed, voluntarily dismissing said counter-claim to be re-filed at a later date.
25.
Despite the preceding fact, the Circuit Court of Baltimore County, MD, in blatant disregard for the lack of jurisdiction entered a void order dismissing Wetzelberger’s counterclaim with prejudice.
26.
While researching the public SEC filings and court cases MTB has been involved in,
Wetzelberger discovered that MTB was caught in a scheme to defraud the U.S. Government via the HUD 203K Program. (Pet. for pre-suit discovery at ¶¶ 45-46). Ironically that same case was filed in the very court that the instant case was removed to. A reasonable person could infer that is not a coincidence.
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Case details are found in the U.S. District Court- Eastern District of N.Y. Pugach et al v. M&T Mortgage Case #CV-05-2498 (emphasis in bold). http://www.prnewswire.com/news-releases/m--t-bank-subject-of-whistle-blower-lawsuit-bankaccused-of-defrauding-government-out-of-millions-from-forged-mortgages-52712792.html
“The whistle blower suit stems from a case involving more than 50 mortgages owned by M&T on properties in Manhattan and Brooklyn that were fraudulently secured through HUD's 203K program for non-profits. A new admission by M &
T's lawyer reveals there are nearly 400 fraudulent mortgages worth a half-
billion dollars.
Indeed, on Friday night, June 29, 2007, Todd Marcus, the attorney for M & T, admitted in a letter to the court that his client never made him aware of a secretive deal between the bank and HUD, in which HUD agreed to pay off not just these 50 fraudulent mortgages, but an astonishing total of 374 fraudulent mortgages worth some $500 million!
Marcus previously represented to the court that M & T had no knowledge of any fraud in the origination of any of these loans.
The deal between M & T was reached six years ago, according to a letter dated January 11, 2001. Although his law partner attended the meeting at which the deal was reached, Marcus told the court on Friday that he was not aware of the agreement or even the letter's existence until April of this year!”
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Taken in sum, a reasonable person, and trier of fact, not suffering under mental disability, can infer that it’s obvious Dore and MTB have something to hide, when they have repeatedly attempted to duck discovery, and obstruct an unrepresented litigant who is not trained in the law. The attempted removal to federal court is just one more attempt to game the system and avoid the inevitable discovery that will prove every statement of fact Wetzelberger has made on the record, in both Maryland and New York courts.
II. The Court Lacks Subject Matter Jurisdiction
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This case must be remanded to state court because this court lacks subject matter jurisdiction. MTB asserts in its Notice of Removal that the claimed basis for removal is federal question jurisdiction. The basis for removal is set forth in 28 U.S.C. § 1331, 1441, 1446 and 15
U.S.C. §§ 77p(c), and 78bb(f)(2).
1. Standard for Removal
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Under 28 U.S.C. § 1446(c)(4), a district court is to examine a notice of removal to determine whether it appears on its face or by any attached exhibits that an order for summary remand must be issued.
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The basis for removal is set forth in 28 U.S.C. § 1441 which provides that removal may occur, regardless of the citizenship of the parties, when the district courts would have original jurisdiction. Original jurisdiction or federal question jurisdiction as defined in 28 U.S.C. § 1331 exists for “civil actions arising under the Constitution, laws, or treaties of the United States.”
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Thus, removal is only proper if the state court actions against Respondents are “civil actions arising under the Constitution, laws, or treaties of the United States.” Federal question jurisdiction only exists if a federal question appears on the face of the complaint
33.
Per C.P.L.R. § 3102(c), the causes of action in Wetzelberger’s counter-claim against respondents in the Maryland court, that was erroneously dismissed by a court lacking jurisdiction, were entirely based on state court claims, not federal law.
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Assuming arguendo, even if the existing counterclaim raised federal issues, the state court can adjudicate those issues. The state court is vested with full authority to hear any and all claims asserted, including Federal Claims, pursuant to the Reverse Erie Doctrine as set down by the High Court in Offshore Logistics v. Tallentire, 477 U.S. 207 (U.S. 1986). In short even if the
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5 case is brought before the state court, the state court must follow federal statutory and general maritime law: See generally Peterson v. United Accounts, Inc . 638 F.2d 1134 (8 th
Cir. 1981):
“We agree with the district court that Burleigh County District Court of the State of
North Dakota, the court before which the state cause of action is pending, is a court of competent jurisdiction under this provision of the FDCPA. Hence, the FDCPA claim may be heard before that state court.”
See also Cooley v. Wachovia, Chase Manhattan et al ., 365 BR 464 (March 13,
2007)
“State Courts have concurrent jurisdiction to hear TILA claims.”
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35.
In determining whether removal is proper under § 1441, the Seventh Circuit advises that a district court must construe the removal statute narrowly and resolve any doubts regarding subject matter jurisdiction in favor of remand. Doe v. Allied-Signal, Inc.
, 985 F.2d 908, 911 (7th
Cir. 1993); Illinois v. Kerr-McGee Chemical Corp.
, 677 F.2d 571, 576 (7th Cir. 1982).
36.
Per 28 U.S.C. § 1332(a), the two mandatory requirements to be met are complete diversity and amount in controversy. In Dublin Worldwide Productions (USA), Inc. v. Jam
Theatricals, Ltd ., 162 F. Supp. 2d 275; 2001 U.S. Dist. LEXIS 14731, Judge Jed S. Rakoff stated as much “[i]t was obvious that such a lawsuit would comport with the requirements of federal subject matter jurisdiction, since there was complete diversity of citizenship between Dublin and
Jam and the amount in controversy exceeded $75,000. See 28 U.S.C. § 1332(a) .” (Pet. App A to
Motion to Remand)
37.
Complete diversity does not exist as every respondent, with the exception of MTB, is a citizen of Maryland, where Wetzelberger is also domiciled. Pre-suit discovery is an equitable remedy and there is no amount in controversy. Hypothetical amounts in controversy amount to
“hypothetical jurisdiction”
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To proceed to the exercise of judicial power before jurisdiction has been established raises both statutory and Constitutional issues. Similar issues were raised by the doctrine of
"hypothetical jurisdiction," which allowed courts to proceed to merits issues even when jurisdiction had not been established. Justice Scalia observed spoke for the Court in rejecting the doctrine in Steel Co. v. Citizens for a Better Environment , 523 U.S. 83 (1998).
Hypothetical jurisdiction produces nothing more than a hypothetical judgment -- which comes to the same thing as an advisory opinion, disapproved by this
Court from the beginning. Much more than legal niceties are at stake here. The statutory and (especially) constitutional elements of jurisdiction are an essential ingredient of separation and equilibration of powers, restraining the courts from acting at certain times, and even restraining them from acting permanently regarding certain subjects. For a court to pronounce upon the meaning or the
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21 constitutionality of a state or federal law when it has no jurisdiction to do so is, by very definition, for a court to act ultra vires. Id. at 101-102 (internal citations and quotation marks omitted).
2.
Respondent’s Additional “Theories” of Removal Fail
39.
15 U.S.C. §§ 77p(c) and 78bb(f)(2) both address class action suits and state as follows (emphasis in bold):
15 U.S.C. § 77p(c)- Removal of covered class actions
Any covered class action brought in any State court involving a covered security , as set forth in subsection (b) of this section, shall be removable to the
Federal district court for the district in which the action is pending, and shall be subject to subsection (b) of this section.
15 U.S.C. § 78bb(f)(2)- Removal of covered class actions
Any covered class action brought in any State court involving a covered security , as set forth in paragraph (1), shall be removable to the Federal district court for the district in which the action is pending, and shall be subject to paragraph (1).
40.
Mr. Schrager got one fact right, and acknowledged and admitted what no other attorney or trier of fact has admitted up until this point. The issue of Wetzelberger’s personal property (both the original, genuine, unaltered, un-bifurcated note and deed of trust) being securities that were illegally converted, bifurcated, pledged, and written to the books of an unknown entity(s) as an off balance sheet item, governed by UCC Article
8 (as adopted in Md and NY), and not a negotiable instrument (in the case of the note) governed by UCC Article 3 (as adopted in Md. and NY).
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However, what Mr. Schrager got wrong is the fact that there is no mention of class action suit in either Wetzelberger’s counter-claim or pre-suit discovery petition.
The law governing securities can also be adjudicated by the state court.
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42.
Respondents have in effect attempted to further obstruct discovery by sidestepping the salient issues of this litigation, and these attempts must not be rewarded. See generally King v.
Anderson Cty , 2010 U.S. Dist. LEXIS 122722 (2010), Bodenner v. Graves , 828 F. Supp. 516
(1993).
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43.
Petitioner is entitled to recover from Respondents its just costs and actual expenses, incurred as a result of the removal pursuant to 28 U.S.C. § 1447(c). An award of costs and fees in this case is proper because Respondents lacked an “objectively reasonable” basis for removal.
MB Fin. Bank, N.A. v. 56 Walker, LLC , 2011 U.S. Dist. LEXIS 145473 (emphasis in bold) (Pet.
App. B to Motion to Remand)
In this case, an award of attorney's fees and costs is warranted because the removing defendants lacked an objectively reasonable basis for seeking removal. The removing defendants asserted that removal was proper based on federal question jurisdiction because the plaintiff's complaint arose under federal law. However, it was clear from the plaintiff's complaint that there was no basis for "arising under" jurisdiction in this case. A claim "arises under" federal law only when, in accordance with the "well-pleaded complaint rule," a
"federal question is presented on the face of the plaintiff's properly pleaded complaint." Rivet v. Regions Bank of La.
, 522 U.S. 470, 475, 118 S. Ct. 921,
139 L. Ed. 2d 912 (1998) (internal quotation marks and citations omitted).
Here, the plaintiff's complaint does not present any federal question but rather asserts only a state law foreclosure claim. While the removing defendants argued that problems with the transfer of the loan and its provenance rendered removal appropriate, these are defenses, rather than the basis for the claim, and do not give rise to federal question jurisdiction . See id. at
478 ( a defendant cannot remove on the basis of a federal defense ); Louisville
& Nashville R.R. Co. v. Mottley , 211 U.S. 149, 152, 29 S. Ct. 42, 53 L. Ed. 126
(1908) (anticipated defense is insufficient to give rise to federal jurisdiction).
The removing defendants also argued that the complaint was merely artfully pleaded to avoid pleading federal law. The "artful pleading" doctrine "rests on the principle that a plaintiff may not defeat federal subject-matter jurisdiction by
'artfully pleading' his complaint as if it arises under state law where the plaintiff's suit is, in essence, based on federal law." Sullivan v. Am. Airlines,
Inc ., 424 F.3d 267, 271 (2d Cir. 2005) . However, there is no federal law underlying this state foreclosure action around which the plaintiff could have artfully pleaded. To the extent that the removing defendants asserted that the plaintiff's complaint was artfully pleaded because the plaintiff's claims are completely pre-empted by federal law, this argument is unpersuasive .
There is no basis to conclude that a mortgage foreclosure action is completely pre-empted by federal law, and, indeed, the removing defendants have cited no case that stands for this proposition. Cf. Rivet , 522 U.S. at 476 (improper to remove an action from state court that sought recognition and enforcement of a mortgage under state law despite a claim of preclusion under prior Bankruptcy
Court orders). Thus, the removing defendants lacked an objectively reasonable basis for removal because federal question jurisdiction was plainly unavailable in this case.
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44.
Also see U.S. Bank NA v. Bey , 2011 U.S. Dist. LEXIS 32086 where defendant attempted to assert a “federal defense” as the basis for removal and was rejected (emphasis in bold) (Pet App. C to Motion to Remand).
Bey also invokes federal question jurisdiction as a basis for removal, arguing in his Notice of Removal that this case implicates his right to Due Process under the Fifth Amendment (Notice at 4), and adding in his Objection to the
Motion to Remand "that all [m]ortgages are governed by Federal Laws which are the ingredients of the original case" (Obj. at 5-6). Plaintiff argues that Bey fails to meet his burden and does not provide any factual support "for the contentions that removal is warranted under the Due Process clause of the 5th
Amendment . . . [or] the federal question doctrine." (Mem. Supp. at 6-7.)
Where removal is premised on a federal question, "[t]he presence or absence of federal—question jurisdiction is governed by the 'well—pleaded complaint rule,' which provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint." Rivet v. Regions Bank of La.
, 522 U.S. 470, 475, 118 S. Ct. 921,
139 L. Ed. 2d 912 (1998) (citations omitted). "[A] case may not be removed to federal court on the basis of a federal defense ." Id.
(citations omitted).
Plaintiff's Complaint reveals an action for foreclosure of mortgage and deficiency relying exclusively on Connecticut law. ( See Compl.) Bey's invocation of his Due Process rights and unsupported argument that all mortgages are governed by federal law notwithstanding, the Complaint itself presents no federal question on its face . To the extent that Bey wishes to invoke a federal statutory defense to this foreclosure action, any such defense is not a proper basis for removal . See Rivet , 522 U.S. at 475 . Bey has accordingly failed to meet his burden to show federal question jurisdiction as a basis for removal.
IV.
Conclusion
45.
Per Fed. R. of Civ. P . Rule 12(h)(3), a federal court has the authority to dismiss a case for lack of subject-matter jurisdiction upon motion of a party or sua sponte , upon its own initiative. As evidenced by another frivolous removal (Pet. App. D, E to Motion to Remand), based on almost identical “theories” as the instant case, the court, on its own motion, clearly seeing that it lacked subject matter jurisdiction, swiftly remanded said case sua sponte with no intervention needed by Plaintiff.
46.
In Dublin , Judge Rakoff, certainly had another point right, that is directly applicable to
Respondents, not petitioner. “This, however, is simply a charade”
WHEREAS, since it is clear the court lacks subject matter jurisdiction, this court should remand the state court petition to the Supreme Court of the State of New York, County of Kings and order an award of costs and expenses, commensurate with reasonable attorneys fees as shall
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26 be established following the remand in favor of Petitioner, due to the time involved in responding to respondents’ erroneous Notice of Removal.
To avoid a further delay or denial of “justice”, Petitioner requests a hearing on this matter so that a court reporter can be present to make a proper record, and all parties can make their statements under oath and penalty of perjury.
Dated this ___ day of_______________________2012
_________________________
Todd Wetzelberger
CERTIFICATE OF SERVICE
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UNDER PENALTY OF PERJURY, I _________________________certify that on this
____ day of _______________, 2012 a copy of the foregoing document filed in the United States
District Court, Easter District of New York was served upon the following recipients via
U.S.P.S. first class.
Thomas P. Dore, Esq.
Shannon Menapace, Esq.
Covahey Boozer Devan and Dore, P.A.
11350 McCormick Rd. Executive Plaza III
Hunt Valley, MD 21031-1002
Gerard F. Miles Jr., Esq.,
Huesman Jones & Miles LLC
11350 McCormick Rd. Executive Plaza III
Suite 905
Hunt Valley, MD 21031-1002
Michael T. Cantrell Esq.
3919 Cloverhill Road
Baltimore Maryland 21208
S. Robert Schrager,
Hodgson Russ LLP, for M&T Bank Corporation
1540 Broadway
New York, NY 10036
____________________________
Todd Wetzelberger
State of _____________________
County of ___________________
BEFORE ME_________________________________, Notary Public, personally appeared
Todd Wetzelberger, identified in accordance with Maryland law, and acknowledged the foregoing document to be his/her act.
in my presence this day of _________________,
2012.
______________________
Notary Public My commission expires:
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