Plaintiffs: Jesse E. Torres III, Jennifer J. Adams
vs.
Defendants: Sophie J. Torres, Jesse E. Torres IV (aka Jesse Stockwell, Jesse E. Stockwell),
Debtmerica, LLC, Donald F. Torres

Massachusetts Civil Docket # BACV2011-00433


October 17, 2011: Motion for Summary Judgement against Sophie J. Torres

  • Exhibits: Index
  • Exhibit A: Contract between Plaintiff Jesse E. Torres III and Defendant Sophie J. Torres: Permanent Transfer of Property Rights
  • Exhibit B: A statement, from the long-time Doctor of Mrs. Torres, Dr. Arthur Crago, that she was of sound mind and body.
  • Exhibit C: A sworn, notarized affidavit from the long term neighbors of Mrs. Torres, the Framsons, stating, among other things, “Sophie J. Torres was as sharp as a 35 year old”
  • Exhibit D: A Federal Certificate of HECM Counseling for Defendant Sophie J. Torres
  • Exhibit E: A sworn Affidavit by the Massachusetts Notary Public attesting to the sworn testimony of the Defendant Sophie J. Torres, that she signed the Contract, as well as all documents that day, by her own free act and not under any duress
  • Exhibit F: Notice of Breach of Contract sent to the Defendant Sophie J. Torres and her Attorney Kathryn Wilson. Include Certified Mail Cards
  • Exhibit G: Defendant Sophie J. Torres on August 8, 2011, filed an Opposition to the Plaintiffs Verified Motion for Mental Exam
  • Exhibit H: The Will of Defendant Sophie J. Torres created using Quicken Will Maker Plus
  • Exhibit I: Registered Power of Attorney of Defendant Sophie J. Torres
  • Exhibit J: Appraisal of Grandma's House
  • Exhibit K: Appraisal of Uncle Fred's House
  • Exhibit L: Sworn affidavit by the witnesses Drew and Gail Framson, in attendance at the time of contract's (and other documents) signing, dated September 19, 2011
  • Exhibit M: Notice to Quit to Evict served on Plaintiffs Jennifer Adams and Jesse Torres III on August 05, 2011
 
  • Exhibit N: Notice of No Trespass served on Plaintiffs Jennifer Adams and Jesse Torres III on August 05, 2011
  • Exhibit O: Combined emails between, Jet III, who was the then Attorney-in-fact of Mrs. Torres, and Mrs. Torres' attorney, Kathryn Wilson of Mackey and Foster, in an attempt to stop Kate from completing a new Will that was being written by Kate for the Defendant Sophie J. Torres
  • Exhibit P: Screenshot of Quicken WillMaker Plus used to execute the Will of Defendant Sophie J. Torres on April 24, 2009
  • Exhibit Q: Photos in support of the failure to complete the construction of Grandma's House
  • Exhibit R: Photos in support of the failure to maintain Uncle Fred's House
  • Exhibit S: Photos in support of failure to maintain Horse Property
  • Exhibit T: Response and Opposition to Motion to Dismiss Debtmerica, certificate of service (Sep 20, 2011)
  • Exhibit U: Response and Opposition to Motion to Dismiss Jesse E. Torres IV (aka Jesse E. Stockwell), certificate of service (Sep 26, 2011)
  • Exhibit V: Memorandum Of Law In Support Of Defendant, Sophie J. Torres, Motion To Dismiss (Aug 4, 2011)
  • Exhibit W: Memorandum Of Law In Support Of Defendant, Debtmerica, Motion To Dismiss (Sep 9, 2011)
  • Exhibit X: Memorandum Of Law In Support Of Defendant, Jesse E. Torres IV (aka Jesse Stockwell, Jesse E. Stockwell), Motion To Dismiss (Sep 14, 2011)
  • Exhibit Y: Signed Replacement Contract to place the Properties into a corporate trust, (“Torres Farm Trust, Inc.”)
  • Exhibit Z: “Notice to Cease and Desist, Intent to Bring Actions” to Defendants Jesse E. Torres IV (aka Jesse Stockwell, Jesse E. Stockwell) and Debtmerica, LLC., and receipts for certified mail, return receipt requested
  • Exhibit AA: CD containing a snapshot of Websites: www.jetiii.com/sophie, www.jetiii.com/waquoit and www.jetiii.com/freshpond/photos.asp on CD as folders: sophie, waquoit and freshpond.