Ms. Robinson delivered her Response to the JPMDL today, and a copy is attached to this e-mail message. Ms. Robinson urges the MDL Panel to deny FHFA’s transfer and consolidation request because — using the words FHFA used to argue against transfer and consolidation of cases in 2012 dealing with real estate transfer taxes — it’s an attempt to game the system and centralize cases in a court that’s delivered a result FHFA likes. Ms. Robinson says the facts underpinning her complaint are different from the facts underpinning the cases Judge Lamberth dismissed and those facts only came to light after Judge Lamberth made his ruling (which is now on appeal). If the MDL Panel finds that transfer and consolidation is appropriate, Ms. Robinson recommends the cases be centralized in the Eastern District of Kentucky. Ms. Robinson opposes any suggestion to centralize the cases in the District of Delaware because the facts underpinning the cases before Judge Sleet are vastly differe!
nt.MDL 2713-0018