The original complaint accuses Walker of trademark infringement and not paying an outstanding early payout balance of $124,011.37.

The motion to dismiss filed Monday, argues the trademark infringement claim is a "pretext to muzzle [Walker's] criticism." Additionally, Walker's filing says the broker never actually signed an agreement in which he would owe an EPO, thereby, the alleged breach of contract claim is void.

In December, UWM sent a cease-and-desist, warning Walker that it was closely monitoring the Facebook group he created and asking the broker to remove all improper use of the wholesale lender's intellectual property. Simultaneously, UWM demanded Walker pay the allegedly owed EPO based on an agreement between both parties. 

The wholesale lender followed up with a suit filed Feb. 14 accusing Walker of using its logo in the Facebook group's banner. The group, which now has over 6,000 members, removed the logo as of early January.

Regarding the EPO balance, Walker did business with UWM as a non-delegated correspondent lender from June 2020 through May 2023. During that time, at least 12 loans delivered by Client Direct Mortgage were paid off within 180 days of disbursement, UWM's original suit states.

Its "failure to pay its early payoff balance is a breach of the correspondent agreement that has caused UWM damage," the lender said in its complaint.

In actuality, the correspondent agreement "is undisputedly not signed by either party and UWM does not even allege that the purported 'amendment' was ever signed," making it unenforceable, says Walker's motion.

"UWM's claims represent nothing more than a vendetta against independent mortgage brokers, like Mortgage Solutions, and their principals, like Walker, who formerly worked with UWM but then chose to leave and work with UWM's competitor, Rocket Pro TPO," the motion filed April 15 said. "Not only does UWM seek to burden and harass those who choose to work with UWM's competitors, UWM also seeks to muzzle any criticism by bringing frivolous claims of trademark infringement in a transparent effort to stifle free speech and debate."

Concurrently, potential litigation may be sprouting up against UWM following an explosive Hunterbrook Media report alleging the megalender pressured brokers to use it and overcharged borrowers. Three shareholder rights law firms said they have launched investigations looking into the Pontiac, Michigan-based lender.

Bragar Eagel & Squire, P.C.,Glancy Prongay & Murray LLP and Law Offices of Howard G. Smith in separate announcements announced they will be looking into whether UWM violated the federal securities law. The law requires for publicly traded companies to keep investors informed regarding their financial health,

All the law firms note Hunterbrook's report and the racketeering consumer class action filed shortly after put pressure on UWM's stock price, causing it to fall by $0.56, or 8.5%, to close at $6.00 per share on April 2, thereby allegedly injuring investors.

It is uncertain exactly what the law firms will be investigating. None of them responded to a request for comment at the time of publication. 

UWM did not immediately respond to requests for comment addressing both Walker's motion and the three firms launching investigations.