we obtained summary judgment on behalf of an elderly woman sued by JP Morgan Chase Bank, N.A. for imposition of an equitable lien. Chase sought to encumber our client’s real property with an equitable lien on the basis that her brother had taken out a loan intended to be secured by the property without being on title to the property. We prevailed against Chase pursuant to the doctrine of laches in summary judgment. Chase made no recovery and paid our client’s costs.