I now had my full complaint prepared, along with an emergency motion for a temporary restraining order, and all other supporting documentation. I also had the proper addresses and procedures for serving papers on the defendants, and was ready to file the complete lawsuit.
On October 21st, 2011, I formally filed my lawsuit, charging the bank with 13 causes of action, including Fraud, Bad Faith, Equitable Estoppel, and violating numerous state and local laws, including the Fair Debt Collection Practices Act (FDCPA), the Truth In Lending Act (TILA), and the Real Estate Settlements Procedure Act (RESPA). I also charged the bank with violating the Cease and Desist Order that Bank of America had signed with the Comptroller of the Currency on April 13, 2011.
A complete copy is available for review here.