, aff'd, No. 21-1176 (1st Cir. Dec. 30, 2021); Bradbury v. Deutsche Bank Nat'l Tr. Co. as Tr. for GSAMP Tr. 2005-WMC1, C. A. No. 18-690WES, 2020 WL 1815897, at *6 (D.R.I. Apr. 10, 2020) (challenge to use of “on or before” should be rejected because it “makes even less sense”), adopted by text order, (D.R.I. June 25, 2020), amended, (D.R.I. Feb. 22, 2021); Citibank, N.A. as Tr. for Am. Home Mortg. Assets Tr. 2006-3, Mortg. Backed Pass-Through Certificates Series 2006-3 v. Caito, C. A. No. 18-427-JJM-LDA, 2019 WL 6896309, at *3 (D.R.I. Dec. 18, 2019) (“on or before” language used in notice tracks Paragraph 22 and does not render notice defective), appeal docketed, No. 20-1100 (1st Cir. Jan. 22, 2020).
Other than in Alabama, it has not been followed outside of Massachusetts. While Massachusetts decisions in the mortgage arena are often viewed as persuasive in Rhode Island, Rhode Island jurists have not relied on Pinti; as reflected in Westlaw, it has been mentioned twice in passing - Citibank v. Caito, C.A. No. 18-427-JJM-LDA, 2019 WL 6896309, at *3 (D.R.I. Dec. 18, 2019); Dan-Harry v. PNC Bank, N.A., C.A. No. 17-136 WES, 2018 WL 1083581, at *7 (D.R.I. Feb. 27, 2018) - but otherwise has not even been cited. The First Circuit's reliance on it in Thompson v. JPMorgan Chase Bank, N.A., 915 F.3d 801, 804-05 (1st Cir. 2019) ("Thompson I"), was withdrawn in part because of the discovery of a Massachusetts regulation that arguably called for the language contained in the notice of default, but also because of the flood of industry commentary regarding Pinti's significant consequences, particularly the cloud on the title of innocent downstream purchasers.Thompson v. JP Morgan Chase, N.A., 931 F.3d 109, 110-11 (1st Cir. 2019) ("Thompson II").