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Real Property – Mortgages – Foreclosure – Substitute Trustee – Securitized Loan

Horvath v. Bank of New York N.A. A Virginia mortgage borrower cannot challenge a note holder's foreclosure, by substitute trustee, on the borrower's Woodbridge property on a theory that only the original lender has authority to foreclose; the Virginia legislature has given parties free rein to assign and transfer notes and the deeds of trust accompanying them.

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