Saturday, March 17, 2012

A CASE OF FORGED DOCUMENTS: William J. Paatalo v. J.P. Morgan Chase Bank

For the second time within March 2012, documents have been filed that indicate that JPMorgan Chase Bank, NA through their attorneys are engaged in the production of forged documents (Deeds of Trust and Adjustable Rate Notes) thus engaging in criminal activity both state and federal and while also attempting to perpetrate a fraud on the courts specifically the US District Court in Billings, Montana and in the US Bankruptcy Court in San Jose, California. This bank is attempting to steal two properties owned by two decent men both of whom are "pro se" in their cases.

Chase is represented by two separate law firms who provided to the two separate plaintiffs documents through exhaustive discovery purported to be "Blue Ink" copies of the original Adjustable Rate Notes and Deeds of Trust on two separate loans in which Washington Mutual Bank, FA is the "Lender." Both loans bear loan numbers bearing the first three as "301."

On March 14, 2012 William J. Paatalo, Plaintiff Pro Se in Paatalo v. JPMorgan Chase Bank, N.A. et al, filed a Declaration of Evidence with the US District Court, District of Montana in Case No. 1:10-cv-00119 regarding the validity and authenticity of the Adjustable Rate Note and Deed of Trust submitted to the Plaintiff by the Defendant, JPMorgan Chase Bank, NA.

On March 8th 2012 Defendant JPMorgan Chase Bank, N.A. ("Chase") through its attorneys Charles Smith, Esq. and Elizabeth Kramer, Esq. submitted an email along with two attached electronic files purporting to contain scanned color copies of the original "Note" and "Deed of Trust" and were transmitted to Paatalo at his email address. These documents have black and white print but show "blue ink" initials and signatures.

On information and belief, Chase was representing these files as digitally scanned representations of the actual original documents (Note and Deed of Trust) corresponding to the files. Paatalo understands that Chase was supplying these files in response to his multiple requests for color copies of the original documents.

Upon opening both attachments, Paatalo magnified the signatures of each document to "800X" on two 17" computer monitors situated side by side. The differences in appearance of the signatures were obvious to him. The signature line on the Deed of Trust was blue but when he moved the "scroll bar" back and forth horizontally on the computer screen with the "Note" signature, the letters in the middle initial and surname filled with unusual colors. Upon information and belief, Paatalo stated that this phenomenon occurs when a document has been altered with a computerized software program such as Adobe Photoshop.

Paatalo further states that the signature line on the Deed of Trust was also "blue" while other signature lines on the document remained "black", an obvious sign that the document had been altered. Paatalo recalls that he signed the original Deed of Trust and Adjustable Rate Note at the closing of the subject property on the same day using the same blue ink pen. Both signatures appear vastly different.

Plaintiff Paatalo submitted the files to Dr. Laurie Hoeltzel, a professional Court Qualifed Document Examiner and Handwriting Expert by forwarding the email from Chase's counsel directly to Dr. Hoeltzel on March 10th, 2012. On March 13th 2012 in San Bernardino, California, she signed a Declaration that was duly notarized.

Dr. Hoeltzel studied and was trained in the examination, comparison, analysis and identification of writing, altered numbers and altered documents, handwriting analysis, trait analysis, including the discipline of examining signatures with over twenty years of experience in this field. She apprenticed under some of the leading qualified Forensic Document Experts in the USA such as Don Lehew of Texas and Curt Baggett of Texas, whom are all internationally renowned handwriting and document examination experts. She served eleven years in the U. S. Air Force, three tours in Iraq. She obtained a PhD from Barron University in Los Angeles.

Dr. Hoeltzel concluded based upon her thorough analysis of the documents (Adjustable Rate Note, Lender Washington Mutual Bank FA dated January 3, 2007; Deed of Trust for same; Second Home rider with same):

1.    Pertaining to the documents, Adjustable Rate Note and the alleged initials and signatures of William J. Paatalo: "It is highly probable the author of the WILLIAM J. PAATALO initials & signatures on the questioned documents were indeed altered."

2.    "This document examiner's professional opinion that WILLIAM J. PAATALO signatures on the questioned documents 'Q1' through 'Q3" are forgeries."

Dr. Hoeltzel is willing to testify to his in a court of law and states "I will prove to the Court that my opinion is correct."


1.    Declaration of Evidence William J. Paatalo v. JPMorgan Chase Bank, NA (Scribd)

2.    Declaration of Evidence James Madison Kelley v. JPMorgan Chase Bank, NA (obtained through PACER)

3.    Declarations of Dr. Laurie Hoeltzel in Paatalo case (Scribd) and Kelley Case (PACER).

Case Number:
October 6, 2010
Montana District Court
Billings Office
Presiding Judge:
Richard F. Cebull
Referring Judge:
Carolyn S Ostby
Nature of Suit:
Contract - Other Contract
Federal Question
Jury Demanded By:


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