the foregoing" and "facts alleged are true and correct to the best of my knowledge and belief". And my first reaction was, "REALLY?" Though there was a stamped, "Authorized Officer" what can it mean to have a paralegal from another state, verify by this seat-of-the-pants manner? He or she would have had no knowledge of the business dealings of the Plaintiff, nor is he or she part of the representing law firm of the Plaintiff. If someone swears under penalty of perjury, shouldn't that person KNOW if the complaint is true, or not? Otherwise, why not grab Tom, Dick or Harry off of the street and have one of them do the same thing? Tom, Dick, or Harry could also swear they've read the complaint and that it's true "to the best of (their) knowledge and belief".Gut says, something not right.
You are right to an extent. The verification page needs to be signed by someone who has knowledge of the case with regards to knowledge of your valid mortgage and note, as well as knowledge of the allegations in the complaint. Now if it is a standard foreclosure complaint, then a paralegal may have knowledge of the typical allegations, which include, (in rough layman's terms) that you took the money and put up the house as security and that you have subsequently fallen behind on your payments. Nevertheless, this does not mean that you don't have any defenses. Verifications are areas that foreclosure defense attorneys, such as myself, attack on a daily basis. I would, however, need to see your complaint before giving you proper advice as to whether or not you have a defense with regards to verification.
Also with regards to a PA paralegal verifying it, it doesn't really matter where the person is located. Most of the foreclosure prosecution firms are large multi-state firms and we do see that a lot of the times, all the work is being done in another state and they just have a local licensed attorney employed to handle court matters.
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