UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
CITY OF ST. CLAIR SHORES GENERAL
EMPLOYEES’ RETIREMENT SYSTEM,
Individually and on Behalf of All Others
LENDER PROCESSING SERVICES,
INC., et al.,
SECOND AMENDED CLASS
ACTION COMPLAINT AND
DEMAND FOR JURY TRIAL
6. The economic downturn, marked by record foreclosure rates, together with
LPS’ improper business model, resulted in a tremendous volume of default work for the
Company to process. LPS – determined to process this work as quickly as possible to drive
market share and profits – employed various illicit practices at its offices (including its
headquarters in Jacksonville, Florida and other offices throughout the United States). Much
of the Company’s illicit activity was conducted through its subsidiaries DocX, LLC
(“DocX”), based in Alpharetta, Georgia, and LPS Default Solutions, Inc. (“LPS Default
Solutions”), based in Jacksonville, Florida and Mendota Heights, Minnesota.
7. These illicit practices were pervasive throughout the Company during the
Class Period and included the fabrication of documents, “robo-signing,” the forging of
documents, improper notarization, violation of security protocols, and the concealment of
known mistakes from courts, attorneys, and clients. For instance, through DocX, the
Company engaged in the wholesale fabrication of mortgage assignments, which were filed
with county clerk offices and used as evidence by LPS’ clients in foreclosure proceedings to
evict homeowners. Moreover, to increase the speed at which it processed mortgage-related
documents, LPS required its employees to engage in “robo-signing” and “surrogate signing.”
“Robo-signing” involved LPS employees signing mortgage-related documents at record
speeds without verifying their accuracy. “Surrogate-signing” or forging, as it was internally
known, involved LPS employees forging the names of various bank officials on these same
mortgage documents. These problematic documents were then improperly notarized by LPS
employees who wholly ignored notarization protocols by failing to verify the signatories’
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