COMMONWEALTH OF
MASSACHUSETTS
Land Court Department
Trial Court
MIDDLESEX, SS.
CASE NO. 25 MISC 000530 (MDV)
PHH Mortgage Corporation
v.
Residential Credit Solutions, Inc.
TO: any former stockholders, officers, creditors, and any other persons claiming any interest in Residential Credit Solutions, Inc., a dissolved Delaware corporation with a former principal place of business in Fort Worth, Texas, or their heirs, devises, legal representatives, successors or assigns
You are hereby notified that a complaint has been filed by the above-named plaintiffs in which you are named as an interested party. This complaint concerns a certain parcel of land in Wilmington, Middlesex County, and said Commonwealth being known as and numbered 15 Massachusetts Avenue. Plaintiff alleges title to the subject property is clouded by an improperly discharged prior mortgage of record granted to First Franklin Financial Corporation recorded at the Middlesex County Northern District Registry of Deeds on May 10, 2004 at Book 17284, Page 1. First Franklin Financial executed an assignment of mortgage in favor of Defendant, Residential Credit Solutions, Inc., which was recorded at said Registry in Book 24382, Page 203. On January 15, 2015, PHH, as servicing agent for Residential, executed a purported Satisfaction of Mortgage recorded with said Registry in Book 28775, Page 166. Plaintiff contends that the Satisfaction has no effect on title because no power of attorney could be located granting authority to PHH to execute the Satisfaction on behalf of Residential. Plaintiff seeks a declaration from the court that the mortgage has been fully satisfied and is equitably discharged of record.
This complaint may be examined at the Land Court, Boston, Massachusetts, or online at www.masscourts.org. Information on how to search Land Court dockets is available on the Land Court website: www.mass.gov/how-to/find-a-land-court-case-docket. A copy of said complaint may also be obtained from plaintiff's attorney.
If you intend to make any defense, you are hereby required to serve upon the plaintiff's attorney, Julie A. Ranieri, Esq., of Korde & Associates, P.C., 900 Chelmsford Street, Suite 3102, Lowell, Massachusetts 01851, an answer to the complaint on or before the tenth day of November, 2025, next, the return day, hereof, and a copy thereof must be filed in this court on or before said day.
If you fail to do so, judgment by default will be taken against you for relief demanded in the complaint. Unless otherwise provided by Rule 13(a), your answer must state as a counterclaim any claim which you may have against the plaintiff which arise out of the transaction or occurrence that is the subject matter of the plaintiffs' claim, or you will thereafter be barred from making such claim in any other action.
CASE NO. 25 MISC 000530 (MDV)
It is ORDERED that notice be given by publishing a copy of this notice once in The Fort Worth Star-Telegram, a publication of general circulation in Fort Worth, Texas, at least thirty days before the tenth day of November, 2025.
Witness, Gordon H. Piper, Chief Justice of the Land Court, the twenty-third day of September, 2025.
Attest:
/s/ Deborah J. Patterson Deborah J. Patterson
Recorder
IPL0276869
Oct 8 2025