Deutsche Bank National Trust Company's
Lawyer Lied to the Court
Lawyer Lied to the Court
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Pins and Needles: health boundaries that bite
IN THE SUPREME COURT OF THE STATE OF NEW MEXICO
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE
Plaintiff – Appellee,
v. Supreme
Court No: 31,175
KAREN MARIE KLINE, Pro Se,
Defendant – Appellant,
CROCKER, LTD., AMERICAN GENERAL
FINANCIAL SERVICES, INC.,
AND MANHATTAN CONDOMINIUM UNIT
OWNERS’ ASSOCIATION,
Defendants – Appellees,
KAREN MARIE KLINE, Pro Se,
Petitoner-in-Redemption – Appellant,
RICHARD B. GREEN,
Purchaser; Cross- and Counter-Petitioner-in-Redemption – Appellee.
PETITION FOR REHEARING PURSUANT TO RULE 12-216
Court of Appeals No. 26,930
First Judicial District Court No. D-0101-CV-2005-00515
1. Richard Leverick, lawyer for plaintiff, Deutsche Bank National
Trust (“Deutsche”), lied to the Court at the Hearing to Confirm Sale,
Partial Transcript, lines 8-11, Exhibit 3(b) of Exhibits 3(a) to Exhibit 3
(c),” when he said he served me the Amended Complaint before I filed
Chapter 13.
2. The dates are clear: I filed my Chapter 13 on March 21, 2005,
Exhibit 1; Richard Leverick served me the Amended Complaint, which
he needed to bring the lien holders before the court, on March 29,
2005, Exhibit 2. He also served each lien holder. Each lien holder was
thereafter named as a defendant, as shown above.
3. Pursuant to 11 U.S.C §362 service of Deutsche’s Amended
Complaint during my Chapter 13 was prohibited.
WHEREFORE in the interest of justice Petitioner requests the Court
reverse the lower courts and, in the general public interest, discipline the
lawyer.
Karen Marie Kline
3255 Calle de Molina
Santa Fe, NM 87507
(505) 471-2367
I hereby certify that a copy of the foregoing Petition for Rehearing
Pursuant to Rule 12-216 was mailed to counsel of record as noted
below on September 22, 2010,
For the Plaintiff - Appellee
Vern Payne Richard Leverick, Esq.
PO 2100 5120 San Francisco Road NE
Los Lunas, NM 87031 Albuquerque, NM 87109
(505) 858-3303
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE
Plaintiff – Appellee,
v. Supreme
Court No: 31,175
KAREN MARIE KLINE, Pro Se,
Defendant – Appellant,
CROCKER, LTD., AMERICAN GENERAL
FINANCIAL SERVICES, INC.,
AND MANHATTAN CONDOMINIUM UNIT
OWNERS’ ASSOCIATION,
Defendants – Appellees,
KAREN MARIE KLINE, Pro Se,
Petitoner-in-Redemption – Appellant,
RICHARD B. GREEN,
Purchaser; Cross- and Counter-Petitioner-in-Redemption – Appellee.
PETITION FOR REHEARING PURSUANT TO RULE 12-216
Court of Appeals No. 26,930
First Judicial District Court No. D-0101-CV-2005-00515
1. Richard Leverick, lawyer for plaintiff, Deutsche Bank National
Trust (“Deutsche”), lied to the Court at the Hearing to Confirm Sale,
Partial Transcript, lines 8-11, Exhibit 3(b) of Exhibits 3(a) to Exhibit 3
(c),” when he said he served me the Amended Complaint before I filed
Chapter 13.
2. The dates are clear: I filed my Chapter 13 on March 21, 2005,
Exhibit 1; Richard Leverick served me the Amended Complaint, which
he needed to bring the lien holders before the court, on March 29,
2005, Exhibit 2. He also served each lien holder. Each lien holder was
thereafter named as a defendant, as shown above.
3. Pursuant to 11 U.S.C §362 service of Deutsche’s Amended
Complaint during my Chapter 13 was prohibited.
WHEREFORE in the interest of justice Petitioner requests the Court
reverse the lower courts and, in the general public interest, discipline the
lawyer.
Karen Marie Kline
3255 Calle de Molina
Santa Fe, NM 87507
(505) 471-2367
I hereby certify that a copy of the foregoing Petition for Rehearing
Pursuant to Rule 12-216 was mailed to counsel of record as noted
below on September 22, 2010,
For the Plaintiff - Appellee
Vern Payne Richard Leverick, Esq.
PO 2100 5120 San Francisco Road NE
Los Lunas, NM 87031 Albuquerque, NM 87109
(505) 858-3303
| Exhibit 1 |
| Exhibit 2, page 1 |
| Exhibit 2, page 2 |
| Exhibit 3, page 1 |
| Exhibit 3, page 2 |
| Exhibit 3, page 3 |