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January, 8th 2018

TO WHOM IT MAY CONCERN

This is a complaint against Kansas attorney [ehan K. Moore* (KS #22081) of Lathrop
Gage LLP,2345 Grand Blvd., Suite 2200, Kansas City, MO64108-2618

*Attorney Jehan K.Moore is a debt collector as defined by 15 u.S. Code § 1692a ofthe
federal Fair Debt Collection Practices Act.

On September 29th, 2017 attorney Jehan Moore sent me an email stating that she was
taking over from Attorney Matt R. Hubbard (who at the time was also with Lathrop Gage
LLP) as attorney for Plaintiff (Wilmington Trust) in a foreclose case against me. There was
no entry of appearance pleading attached to this email.This is improper and violates
Kansas supreme court rule Rule 117 (c) .

I only discovered her email in my email spam folder on November 6th, 2017.

It is not until around October 14th, 2017, that attorney [ehan Moore mailed me her formal
notice of appearance in the case via first class mail.

Going back to October 17th, 2016 I was repeatedly denied immediate loss mitigation
options when I requested them, and more importantly I have been denied direct access to
Wells Fargo - the alleged servicer of the loan in question - in violation of 12 C.F.R.§ 1024.41
and 12 C.F.R.§ 1024.40 "Continuity of contact" respectively.

The pressing issues here are that since there was a clear substantial delay in beginning the
loss mitigation process the late fees keep piling up, and that the attorneys are violating my
privacy by insisting that all personal documents needed to be filled for the loss mitigation
be sent through them. I have repeatedly objected to this practice.

As indicated by 12 C.F.R.§ 1024.40 attorney [ehan Moore is not a servicer, and she is not a
servicer personnel, and she has no federal authority to handle any of my personal/private
information. I demand that she immediately provides me with a live contact from the
servicer and that she immediately confirms that she has deleted/destroyed any
information that was sent through her - against my "on the record" objections - as an
unauthorized conduit for the servicer.

The 2016 CFPB"Final Amended Rules" require mortgage servicers to exercise reasonable
diligence to obtain information not in the borrower's control, mandate that servicers
attempt to evaluate an application while waiting for third-party information, and prohibit
servicers from denying borrowers loss mitigation solely on the basis of not having third-
party information.

The servicer must "exercise reasonable diligence in obtaining documents and information
to complete a loss mitigation application."

Attorney [ehan Moore's email to me from January 3rd, 2018 clears implies to me that she
personally sent that email demanding more information and that she is personally involved
in reviewing my private/personal information and loss mitigation application - against my
objections. There is NO iota of indication that she sent this email on behalf of another party.
She has no authority, right, or privilege to interfere with direct communication with the
servicer. She also has no right to make demands as if she were the servicer, or servicer
personnel. This is improper and misleading and as a debt collector she I believe and allege
that she is making false misrepresentations in violation of 15 U.S. Code § 1692e.

Ialso state, believe, and allege that throughout this pending case there has been violations
of 12 C.F.R. § 1024.35, and/or 12 C.F.R. § 1024.36, and/or 12 C.F.R. § 1024.41(b)(1).

Please investigate these matters.

All the necessary documentation supporting this complaint have been attached.

Respectfully submitted,

By: -f:V C NWeMW


<

Eric Muathe,
P.O. Box 224,
Pittsburg, Kansas, 66762
(913) 980-7286

Cc:

v' Office of the Disciplinary Administrator


v' Consumer Financial Protection Bureau
v' Lathrop Gage LLP
1/6/2018 Gmail- Wilmington Trust v. Eric Muathe

MGmaH Eric Muathe <muathedotcom@gmail.com>

.. _ ..... --.. ----


Wilmington Trust v. Eric Muathe
12 messages

Moore, Jehan Kami! (LG) <jmoore@lathropgage.com>


To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,

I
~
My Name is Jehan Moore and I will be taking this matter over from Matt Hubbard. Attached are two letters from Wells Fargo regarding your request for mortgage
assistance. We also mailed these letters to you earlier this week. Please send all future documentation and correspondence on this case to my attention. Please let
me know if you have any questions.

Thank you,

Jehan Moore "


OfCounsef

_LATHROP
_GAGE
Lathrop Gage LLP
2345 Grand Blvd .. Suite 2200
Kansas City, MO 64108·2618
Direct: 816.460.5543
imoore@lathropgage.com
iathropgage.com
------ --------_._._-------_._-
This e-mail (including any attachments) may contain material that (1) is confidential and for the sole use of the intended recipient, and (2) may be protected by the attorney-client privilege, attorney
work product doctrine or other legal rules. Any review, reliance or distribution by others or forwarding without express permission is strictly prohibited. If you are not the intended recipient, please
contact the sender and delete all copies.

2 attachments

~ 0158531384AIRl.PDF
5865K

~ 20170926155547.pdf
, 202K

----_._--_ •... _. __ ._-


Moore, Jehan Kamil (LG) <jmoore@lathropgage.com> Fri, Nov 3,2017 at 4:24 PM
To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,

I am following up on my email below. Please let me know if you intend to send me the documentation needed regarding your request for mortgage assistance.
Please let me know if you have questions. ""

Thank you,

Jehan Moore
Of Counsel
Lathrop Gage LLP
2345 Grand Blvd .. Suite 2200
Kansas City. MO 64108-2618

Direct:816.460.55431
Fax: 816.292.2001
jmoore@iathropgage.com
1/6/2018 Gmail - Wilmington Trust v. Eric Muathe

From: Moore, Jehan Kamil


Sent: Friday, September 29, 2017 10:41 AM
To: Eric Muathe
Subject: Wilmington Trust v. Eric Muathe

Mr. Muathe,

My Name is Jehan Moore and I will be taking this matter over from Matt Hubbard. Attached are two letters from Wells Fargo regarding your request for mortgage
assistance. We also mailed these letters to you earlier this week. Please send all future documentation and correspondence on this case to my attention. Please let
me know if you have any questions.

Thank you,

Jehan Moore
Of Counsel

_LATHROP
_GAGE
Lathrop Gage LLP
2345 Grand Blvd., Suite 2200
Kansas City, MO 64108-2618
Direct: 816.460.5543
jmoore@lathropgage.com
lathropgage.com

This e-mail (including any attachments) may con lain material lhat (1) is confidential and for the sole use of the intended recipient, and (2) may be protected by the attorney·client privilege,
attorney work product doctrine or other legal rules. Any review, reliance or distribution by others or forwarding without express permission is strictly prohibited. If you are not the intended
recipient, please contact the sender and delete all copies.

Eric Muathe <muathedotcom@gmail.com> Mon, Nov 6, 2017 at 8:59 AM


To: "Moore, Jehan Kamil (LG)" <jmoore@lathropgage.com>

Hi Jehan,

I trust you had a great weekend. I apOlogize for the delay since I just saw your email in my spam folder.

In response to your email I had to wait to get additional bank statements, and employee pay stubs and as you know it means having to wait until the end of the month
to get some of these documents.

Needless to say, YES, I will be sending the additional documentation as soon as possible.

Thanks.

Eric Muathe
[Quoted text hidden!

"And therefore our contemplation of this source, as the power which we want, gives us the ability to use that power. And the way we use this process is to contemplate
ourselves as surrounded by the conditions which we want to produce." - Thomas Troward.

Namaste,
Eric Muathe
CEO I Founder
Encare Financial lnc.
http://www.muathe.com

Eric Muathe <muathedotcom@gmail.com> Thu, Nov 30, 2017 at 2:33 PM


To: "Moore, Jehan Kamil (LG)" <jmoore@lathropgage.com>

Hi Jehan,

How are you doing?

Here is a quick update. Once the new month begins I will have new statements, payment stabs and so on which can be induded in my response.

I was working on my response and realized that on page two (of the 5.7MB attachment you emailed me) it indicates that I have until December 20th, 2017 to respond
with additional information. I will respond before then.

Thanks.
1'5/2018 Gmail - Wilmington Trust v. Erie Muathe

Eric Muathe
[Quoted text hidden]

Eric Muathe <muathedotcom@gmail.com> Man, Dec 18, 2017 at 9:26 AM


To: "Moore, Jehan Karnil (LG)" <jmoore@lathropgage.com>

Jehan,

Good morning.

Kindly find attached the ADDITIONAL REQUESTED Loan Modification Documents dated 12-18-2017.

I will appreciate it if you can confirm receipt of the attachment.

Thanks + Bless.

Eric Muathe
[Quoted text hidden]

'ILJ Loan Modification ADDITIONAL REQUESTED Documents 12-18-2017.pdf


r- 25084K

Moore, Jehan Kamil (LG) <jmoore@lathropgage.com> Man, Dee 18, 2017 at 1:00 PM
To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,

I have received the additional documents.

Thank you,

Jehan Moore
01 Caunsel
Lathrop Gage LLP
2345 Grand Blvd .• Suite 2200
Kansas City. MO 64108·2618
Direct: 816.460.5543 I Fax: 816.292.2001
jmoore@!athropgage.com

From: Eric Muathe [mailto:muathedolcom@gmail.com]


Sent: Monday, December 18, 20179:27 AM
To: Moore, Jehan Kamil
Subject: Re: Wilmington Trust v. Eric Muathe

[Quoted text hidden]

Eric Muathe <muathedotcom@gmail.com> Man, Dec 18, 2017 at 1:08 PM


To: "Moore, Jehan Kamil (LG)" <jmoore@lathropgage.com>

[Quoted text hidden]

Moore, Jehan Kamil (LG) <jmoore@lathropgage.com> Tue, Dee 19, 2017 at 2:16 PM
To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,
1/6/2018 Gmail - Wilmington Trust v. Eric Muathe

The following items are still needed in connection with your request for mortgage assistance. If we do not receive these items by December 26, 2017, we will not
be able to continue with your request for a loan modification. Please email me the following items as soon as possible and please let me know if you have any
questions.

We need the following for Eric Muathe:

1. Please provide a letter of explanation regarding why you have not filed tax returns since 2008 per the letter you provided.

2. Please provide a lelter confirming whether or not Kyle Muathe is another contributor. If not please explain your relationship to this person due to the account
detail we received titled Kyle Muathe.

3. Please provide a copy of the year-to-date profit and loss statement for Encare Financial Inc. Muathe.com. The profit and loss should include all gross income
received for the business, a breakdown of each expense, and the total net income.

4. Please provide a signed copy of the most recent filed federal tax returns with all pages and schedules for each borrower or non-borrower who is contributing
income to the household. Please provide tax extensions for each year after that that have not been filed.

5. Please provide a signed copy of the most recent filed business federal tax returns with all schedules for Encare Financial Inc. Muathe.com. If you do not have
business taxes, please provide a letter stating so and the reason why.

6. Please provide a completed, signed, and dated IRS Form 4506T for Eric Muathe.

We also need the following for Jaimi Dodson:

1. Please provide a signed and dated letter stating your employment start date.

2. Please provide a letter of explanation regarding the $500 income that was listed on your paystub. What is this, how often is it received, and will you expect it to
continue?

3. Please provide a copy of your two most recent bank statements showing deposit amounts and balances for your rental income. (The statements provided were
from your savings account.)

4. Please provide the IRS Form 4506-T (Request for Transcript of Tax Return) completed, signed and dated for each borrower or non-borrower who is
contributing income to the household or a copy of your most recent signed federal tax returns (The IRS Form 4506T you sent was incomplete and the taxes were
not signed.)

Thank you,

Jehan Moore
Of Counsel
Lathrop Gage LLP
2345 Grand Blvd., Suite 2200
Kansas City. MO 64108-2618
Direct: 816.460.55431 Fax: 816.292.2001
jmoore@iathropgage.com

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Monday, December 18, 2017 9:27 AM
To: Moore, Jehan Kamil
Subject: Re: Wilmington Trust v. Eric Muathe

[Quoted text hidden]

Eric Muathe <muathedoteom@gmail.com> Tue, Dee 19, 2017 at 2:24 PM


To: "Moore, Jehan Kamil (LG)" <jmoore@lathropgage.com>
1/R./2018 Gmail - Wilmington Trust v. Eric Muathe

Jehan,

Thanks. Just happen to see your email...

Yes, I do have a question.

Who is requesting this information since any communication needs to come directly from the servicer - I believe that is the indication from the Dodd-Frank
~ act?..q _
From the very beginning I objected to your involvement as a conduit for communications with the servicer since most of the information I am proving is frankly
supposed to be private information that raises glaring issues of privacy - which I object to.

Regards,

Eric Muathe
[Quoted text hidden)

Moore, Jehan Kamil (LG) <jmoore@lathropgage.com> Thu, Dec 21, 2017 at 11:43 AM
To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,

Wells Fargo is requesting the information. I am an attorney for Wells Fargo and I am acting on behalf of Wells Fargo. Please let me know if you intend to provide
the missing items.

Thank you,

Jehan Moore
Of Counsel
Lathrop Gage LLP
2345 Grand Blvd., Suite 2200
Kansas City, MO 64108·2618
Direct: 816.460.5543 I Fax: 816.292.2001
jmoore@lathropgage.com

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Tuesday, December 19, 2017 2:24 PM

[Quoted text hidden]

[Quoted text hidden)

Eric Muathe <muathedotcom@gmail.com> Wed, Dec 27, 2017 at 1:15 AM


To: "Moore, Jehan Kamil (LG)" <jmoore@lathropgage.com>

Jehan,

It seems to me that Wells Fargo did not take a look at page two (2) of the pdf document I had emailed you to forward to Wells Fargo since the information Wells Fargo is
requesting was addressed on that page (page two).

Thanks.

Eric Muathe
[Quoted text hidden)

._---- - ---- --_._-------------_.


Moore, Jehan Kamil (LG) <jmoore@lathropgage.com>
To: Eric Muathe <muathedotcom@gmail.com>

Mr. Muathe,
??? Wed, Jan 3, 2018 at 10:38 AM

Please let me know if you intend to provide the missing documentation listed below. I need this documentation as soon as possible or Wells Fargo will not be able
to proceed with your request for mortgage assistance.

We need the following for Eric Muathe:


1/6/2018 Gmail - Wilmington Trust v. Eric Muathe
1. Please provide a letter of explanation regarding why you have not filed tax returns since 2008 per the letter you provided.

2. Please provide a letter confirming whether or not Kyle Muathe is another contributor. If not please explain your relationship to this person due to the account
detail we received titled Kyle Muathe.

3. Please provide a copy of the year-to-date profit and loss statement for Encare Financial Inc. Muathe.com. The profit and loss should include all gross income
received for the business, a breakdown of each expense, and the total net income.

4. Please provide a signed copy of the most recent filed federal tax returns with all pages and schedules for each borrower or non-borrower who is contributing
income to the household. Please provide tax extensions for each year after that that have not been filed.

5. Please provide a signed copy of the most recent filed business federal tax returns with all schedules for Encare Financial Inc. Muathe.com. If you do not have
business taxes, please provide a letter stating so and the reason why.

6. Please provide a completed, signed, and dated IRS Form 4506T for Eric Muathe.

We also need the following for Jaimi Dodson:

1. Please provide a signed and dated letter stating your employment start date.

2. Please provide a letter of explanation regarding the $500 income that was listed on your paystub. What is this, how often is it received, and wil! you expect it to
continue?

3. Please provide a copy of your two most recent bank statements showing deposit amounts and balances for your rental income. (The statements provided were
from your savings account.)

4. Please provide the IRS Form 4506-T (Request for Transcript of Tax Return) completed, signed and dated for each borrower or non-borrower who is
contributing income to the household or a copy of your most recent signed federal tax returns (The IRS Form 4506T you sent was incomplete and the taxes were
not signed.)

Thank you,

777
Jehan Moore
Partner
Lathrop Gage LLP
2345 Grand Blvd., Suite 2200
Kansas City. MO 64108-2618
Direct: 816.460.55431 Fax: 816.292.2001
jmoore@!athropgage.com

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Wednesday, December 27,20171:15 AM

[Ouoted text hidden]

[Quoted text hidden]


JEHAN KAMIL MOORE
LATHROP OF COUNSEL
•• GAGE DIRECT: 816.460.5543

MAIN: 816.292.2000
FAX: 816.292.2001
JMOORE@LATHROPGAGE.COM
LATHROPGAGE.COM

2345 GRAND BOULEVARD, SUITE 2200


KANSAS CITY, MISSOURI 64108-2618

September 26,2017

VIA FEDERAL EXPRESS

Eric Muathe
1410 Bitner Terrace
Pittsburg, KS 66762

Re: Wilmington Trust v. Eric Muathe

Dear Mr. Muathe:

Enclosed is correspondence from Wells Fargo requesting additional documentation in


connection with your request for mortgage assistance. Please send the additional
documentation to my attention.

Very truly yours, t


Lathrop Gage LLP

f
I
'
By: ~L~.~*-
__~~~~~ _
Jeha

JKM/adg
IN THE DISTRICT COURT OF CRAWFORD COUNTY, KANSAS

WILMINGTON TRUST N.A., )


)
Plaintiff, )
v. )
Case No. 2014 CV 86 P
)
ERIC M. MUATHE, )
)
Defendant. )

NOTICE OF WITHDRAWAL OF COUNSEL AND


ENTRY OF APPEARANCE OF SUBSTITUTED COUNSEL

Matthew Hubbard, counsel of record for Plaintiff Wilmington Trust, N.A., hereby

withdraws as counsel of record for said Plaintiff. Michael Abrams and Jehan Karnil Moore of the

law firm of Lathrop Gage LLP hereby enter their appearance as counsel of record in this case in

substitution of withdrawing counsel. All future pleadings and correspondence should be directed

to Michael Abrams and Jehan Kamil Moore at the email and physical addresses reflected below.

28115680vl
LATHROP GAGE LLP

By: /s/ lehan Kamil Moore


Michael 1. Abrams KS #15407
Jehan Kamil Moore KS #22081
2345 Grand Avenue, Suite 2200
Kansas City, Missouri 64108-2684
Telephone: 816.292.2000
Facsimile: 816.292.2001
ATTORNEYS FOR PLAINTIFF
WILMINGTON TRUST N.A.

By: /s/ Matt R. Hubbard


Matt R. Hubbard KS #18016
2345 Grand Blvd., Ste. 2200
Kansas City, MO 64108-2618
Telephone: (816) 292-2000
Telecopier: (816) 292-2001
mhubbard @lathropgage.com
WITHDRAWING ATTORNEY FOR
WILMINGTON TRUST, N.A.

CERTIFICA TE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing was filed electronically

with the Court on October 11, 2017, and sent via U.S. Mail to the following:

Eric Muathe, Defendant (pro se)


1410 Bitner Terrace
Pittsburg, Kansas 66762

/s/ Jehan Kamil Moore


An Attorney for Plaintiff Wilmington Trust, N.A.

2
28115680vl
1/6/2018 Gmail - Case Number 2014 CV 86P [For Settlement Purposes ONLY]

M Gmail Eric Muathe <muathedotcom@gmail.com>

---------------- -.---_.
Case Number 2014 CV 86P [For Settlement Purposes ONLY]
13 messages
.--------------_. --------------------- ------_. __ .... _-------_._--_.
Eric Muathe <muathedotcom@gmail.com>
To: "Hubbard, Matthew (LG)" <mhubbard@lathropgage.com>, cbush@km-Iaw.com, James Nelson <jnelson@km-Iaw.com>

Hi Matt,

I trust you had a great weekend.

I thought it wise to see if you had a "contact person" with whom I would discuss any out of Court settlement options. At this point I honestly don't even know who I would
approach to do that.

I have copied Charles Bush and James Nelson of Kozeny & McCubbin, L.C., and Wendy M. Green' and Linda S. Mock' formerly with the Law-firm Shapiro and Mock,
LLC (now DBA Shapiro & Kreisman, LLC) due to their previous involvement in the current and previous action on the same subject matter property as seen in the
attachment.

'Via Fax.

I will be adding them all, and JPM Chase, to any counter lawsuit in state andlor federal court - at the very least - not to mention appearing as witnesses in the current
lawsuit.

In the spirit of judicial economy this email is worth your kind consideration.

Bless!

''And therefore our contemplation of this source, as the power which we want, gives us the ability to use that power. And the way we use this process is to contemplate
ourselves as surrounded by the conditions which we want to produce. "- Thomas Troward.

Namaste,
Eric Muathe
CEO I Founder
Encare Financial Inc.
http://www.muathe.com

~ Foreclosure-Dismissal (1).pdf
, 438K

-------_._--------_ .._-_._--
Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Mon, Oct 17, 2016 at 4:37 PM
To: Eric Muathe <muathedotcom@gmail.com>

Eric:
I will double check, but I believe any settlement discussions regarding our Wilmington Trust court case will likely be handled by me. I will check with the client and get
back to you. ...., -----....,~
Thanks,
Matt

Sent from my iPhone

This e-rnail (including any attachments) may contain material that (1) is confidential and for the sole use of the intended recipient, and (2) may be protected by the
attorney-client privilege, attorney work product doctrine or other legal rules. Any review, reliance or distribution by others or forwarding without express permission is
strictly prohibited. If you are not the intended recipient, please contact the sender and delete all copies .
._----- -
.. -_._----_._- ... _._-------

On Oct 17, 2016, at 12:47 PM, Eric Muathe <muathedotcom@gmail.com> wrote:

[Quoted text hidden]

<Foreclosure-Dismissal (1 ).pdf>

Eric Muathe <muathedotcom@gmail.com> Tue, Oct 18. 2016 at 10:04 AM


To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Good Moming Matt.

Thanks. I guess the most pressing questions are what will it take for your client to setHe out of Court, or IF that is even an option?

~Of course, ------------------------------------------------------~---


ideally. this should be done as early in the process as possible - in the interest of Judicial economy.

~-------~--------------------------=----------~~
1/6/2018 Gmail - Case Number 2014 CV 86P [For Settlement Purposes ONL Yj

Bless.

Eric Muathe

[Quoted text hidden]

-------- ----
Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Wed, Oct 19, 2016 at 1:08 PM
To: Eric Muathe <muathedotcom@gmail.com>

Eric:

I confirmed that I will be communicating with you regarding any settlement discussions, We don't know if it is an option, but we will communicate any settlement
offer you make to the client for its consideration. ~ •

Thanks

From: Eric Muathe [mailto:muathedotcom@gmaiLcom]


Sent: Tuesday, October 18, 2016 10:04 AM
To: Hubbard, Matt
Subject: Re: case Number 2014 CV86P [For Settlement Purposes ONLY]

[Quoted text hidden]

Eric Muathe <muathedotcom@gmail.com> Wed, Oct 26, 2016 at 8:37 AM


To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Good morning Matt,

How are you doing? I was curious as to what the payoff amount is for this account?

Again, only for settlement purposes and considerations.

Good day and bless.

Eric Muathe
[Quoted text hidden]

Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Wed, Oct 26,2016 at 10:51 AM


To: Eric Muathe <muathedotcom@gmaiLcom>

I will check and get back to you asap. Thanks Eric

from: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Wednesday, October 26, 20168:37 AM
[Quoted text hidden]

[Quoted text hidden]

Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Fri, Oct 28,2016 at 10:05 AM


To: Eric Muathe <muathedotcom@gmail.com>

Eric:

1. I have Wilmington Trust's documents and its responses to your First Request for Production of Documents, and I will mail them to you today.

2. I have requested an itemized payoff of the Loan and I will send that to you as soon as I get it, per your request.

3_ I am awaiting Wilmington Trust's signatures for its responses to your First Interrogatories and First Requests for Admissions. These are due in the next few
days, but I will be out of town next week, and I request a short extension of time until Nov, 11th to get you these signed responses to your First Interrogatories and
First Requests for Admissions.. Is this short extension ok with you?
1/6/2018 Gmail- Case Number 2014 CV 86P [For Settlement Purposes ONLY]

Thanks,
Matt

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Wednesday, October 26, 2016 8:37 AM

[Ouoted text hidden]

[Quoted text hidden)

._--_._. -------
Hubbard, Matthew (lG) <MHubbard@lathropgage.com> Fri, Oct 28,2016 at 12:08 PM
To: Eric Muathe <muathedotcom@gmail.com>

Eric:
Today I will do a short motion for extension oftime to serve our responses to your discovery requests until Nov. 11,2016, so please let me know if the short
extension is ok with you.
Thanks

From: Hubbard, Matt


Sent: Friday, October 28,2016 10:05 AM
To: 'Eric Muathe'
Subject: RE: Case Number 2014 OJ 86P [For Settlement Purposes ONLY]

Eric:

1. I have Wilmington Trust's documents and its responses to your First Request for Production of Documents, and I will mail them to you today.

2. I have requested an itemized payoff of the Loan and I will send that to you as soon as I get it, per your request.

3. I am awaiting Wilmington Trust's signatures for its responses to your First Interrogatories and First Requests for Admissions. These are due in the next few
days, but I will be out of town next week, and I request a short extension of time until Nov. 11th to get you these signed responses to your First Interrogatories and
First Requests for Admissions.. Is this short extension ok with you?

Thanks,
Matt

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Wednesday, October 26, 20168:37 AM
[Quoted text hidden]

[Quoted text hidden]

---------------------------------------------------- -------
Eric Muathe <muathedotcom@gmail.com> Fri, Oct 28,2016 at 3:28 PM
To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Hi Matt,

I don't have any objection to the extension you are asking for.

Have a great weekend.

Bless.

Eric Muathe
[Quoted text hidden]

- •. --. - - ------- ------------------- --------------_ __


.. ... - .-
Hubbard, Matthew (lG) <MHubbard@lathropgage.com> Fri, Oct 28,2016 at 3:29 PM
To: Eric Muathe <muathedotcom@gmail.com>
1/6/2018 Gmail- Case Number 2014 CV 86P [For Settlement Purposes ONLY]

Ok Thanks Will file motion

From: Eric Muathe [mailto;muathedotcom@gmail.com]


Sent: Friday, October 28, 2016 3;29 PM

[Quoted text hidden]

[Quoted text hidden]

Hubbard, Matthew (LG) <MHubbard@lathropgage.com>


Wed, Nov 2, 2016 at 10;01 AM
To: Eric Muathe <muathedotcom@gmail.com>

Eric:

Please recall your request for the account payoff amount. The account payoff (without attorney's fees) is approximately $290.709.02.

See attached affidavits. The per diem is approximately $33.34. The above 290k amount is calculated as $285,608 (as of 5/24116) + ($5,101.02 interest from
5125116 through 1112116) = $290,709.02.

Thanks,
Matt

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Wednesday, October 26, 20168:37 AM

[Quoted text hidden]

[Quoted text hidden]

~ 26505658_1.PDF
205K
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Eric Muathe <muathedotcom@gmail.com> Mon, Nov 28,2016 at 9;59 AM


To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Good morning Matt,

I would like to make a settlement offer for you and your client to reconsider - for settlement purposes only.

To date, I have not heard any settlement propositions from your end and wonder if your client even wants to consider any settlement possibility for judicial economy.

I am willing to consider a reworked loan agreement - at a competitive fixed interest rate - for the amount sued upon (about 178K), and receive a personal judgment
against me for the remaining amount ( approx. 290K - approx. 178K = approx. 112K ) PLUS attorney fees.

If this is something your client can have good faith discussions on do kindly let me know.

Thanks.

Eric Muathe
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Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Mon, Nov 28,2016 at 10:07 AM


To: Eric Muathe <muathedotcom@gmail.com>

Good Morning Eric:

I hope you had a good weekend. I will confer with the bank and let you know their response.

Thanks,

Matt
1/6/2018 Gmail - Case Number 2014 CV 86P [For Settlement Purposes ONLY]

Lathrop & Gage, LLP

Partner
2345 Grand Blvd. I Suite 2200 I Kansas City, MO I 64108-2618
P: 816.460.5528 I F: 816.292.2001 I MHUBBARD@LATHROPGAGE.COM

Los Angeles ' Denver . Boulder . Chicago . Overland Park . Kansas City . Springfield . Jefferson City . St. Louis . Boston

From: Eric Muathe [mailto:muathedotcom@gmail.com]


Sent: Monday, November 28, 20169:59 AM
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