The Law Offices of Rory Rohan
Aggressive Foreclosure Defense
If Rory is retained, you might expect the following:
- Preparation and filing of insightful and proper pleadings, documents and discovery materials
- Motion to Dismiss or Alternatively For a More Definite Statement: Often times the plaintiff Bank or Servicer fails to identify themselves or fails to properly plead ownership of the note and or mortgage in the complaint. We will forcefully challenge every allegation made by the plaintiff.
- Enhanced and specific Discovery Materials: we will file well crafted;
- Requests for Admissions—forcing the plaintiff to admit whether they properly own and hold the note and mortgage and whether they were in possession of the note when it was lost
- Requests for Production—forcing the plaintiff to produce the documents that delineate the chain of title of the note
- Written Interrogatories—forcing the plaintiff to answer the tough questions necessary before proceeding with a foreclosure
- Motion To Compel—Should the plaintiff fail to respond to the discovery requests within the proper thirty day period we will seek an Order from the Judge forcing the plaintiff to respond. If the plaintiff fails to respond we will use that failure to prevent them going forward with the foreclosure.
- Response to Motion For Summary Judgment: We will prepare and file a proper response to every Motion for Summary Judgment filed by a plaintiff including memorandum of law and recent and controlling case citations in a legal and thoughtful effort to prevent a Summary Judgment from being entered against you.
- Loan Modifications and Short Sales: Beware of loan modifications and short sales that do not fully protect you
- We can provide assistance with loan modifications making sure that you are protected from suspense accounts and other tricks employed by the Servicer to obtain payments from you to fund the foreclosure against you.
- Short sales that do not address the deficiency judgment are of little or no value to the borrower. We provide you with proper advice regarding each and every issue involving a short sale. Protecting you is the goal.


