Here's the appeal we filed in the 11th Circuit & Locke Lord law firm response for their client Select Portfolio Servicing.
Oral argument each side gets 15 mins each.
SPS is telling the 11th circuit it rather spend hundreds of thousands dollars then to produce a certified copy of the note in its current condition.
You will noticed the back of SPS monthly statement before we filed our lawsuit they never thought it was important to following the law in regards to Qualified Written Requests and never even designated an exclusive address as required under Federal law.
SPS changed the back of monthly statements on February 2014 to comply with the Federal Law