Excerpt:

Trudy Kalush, Debtor and Debtor-in-Possession herein (“Debtor”), hereby files her Opposition to the Motion to Reconsider Order Sustaining Objection to Claim No. 6 (“Claim No. 6”) (the “Motion”) filed by Deutsche Bank National Trust Company, as Trustee of the IndyMac INDX Mortgage Loan Trust 2005-AR12, Mortgage Pass-Through Certificates, Series 2005-AR12 under the Pooling and Servicing Agreement dated June 1, 2005 (“Deutsche Bank”). First and foremost, Deutsche Bank’s counsel should be sanctioned pursuant to a separately filed motion for their outright fraud on the Court. What Deutsche Bank fails to tell the Court is that Michael B. Shaw is a Texas attorney that signed Claim No. 6 as “Creditor’s Authorized Agent” and at the time he signed Claim No. 6 he worked for the Brice Firm (as defined below). The Brice Firm is the same firm filing the Motion and never once informs the Court of this fact, nor does it attach a declaration of Mr. Shaw, who was sent letters, discovery pleadings, etc. Typical games of disputed lenders, and no facts or law is presented to support the Motion. Rather, it appears Deutsche Bank has claims against its counsel, which is of no concern to Debtor or the Court.

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