I am working on it

I had a bank send me some loan documents through the mail. They told me in an email to sign the loan docs and also stated they were only renewing the loans for one year unless I could get my cash flows up.
When I sent the documents back they added a notary acknowledgement page and "willfully and falsely" notarized the deeds of trust and recorded them in the Chancery Clerks office.
I found out about this months later. Not knowing what to do I subscribed to Dr. Graves course.
I filed a document on public record an affidavit stating I did not appear before the notary and the certificate is false.
I also confronted the bank about this in many certified letters to the bank and their attorney. They acted with impunity towards me and the law.
They they called my note due after I confronted them about this. They stated they would place my payments in trust pending directions from the courts for a judicial foreclosure.

Using discovery I got an admission of the illegal act and in interrogatories. The notary confessed and also the bank officer and the bank confessed the circumstances of the forge.

They were able to foreclose even though I fought it in the Judicial foreclosure. Because I received the benefit and the property was used as collateral the bank was successful and was granted the right to foreclose.
Months later after the foreclosure, the bank now is coming after me for a deficiency judgement.
I filed a Motion to Dismiss 12(b) (7) Rule 19 Failure to add an indispensable party to resolve all issues. This motion is set to be heard in mid Sept.
Now I am working on this motion - a Declaratory Judgement seeking a determination of improper and false notary certificate on the deed of trust.
I will be using as a counter claim the following: THE DOCTRINE OF RESPONDENT SUPERIOR, BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING, BREACH OF DUTY OF FAIRNESS, INTENTIONAL AND NEGLIGENT INFLICTION OF EMOTIONAL
Affermative Defenses include: IN PARI DELICTO, FORGE
OF NOTARY CERTIFICATE,MISREPRESENTATION

unclean Hands, and anything else I can think of...