In Bank of New York Mellon v. De Meo 227 Ariz. 192, 254 P.3d 1138 (Ariz.App. 2011), Division One of the Arizona Court of Appeals set aside an eviction of a tenant from a residence on the grounds that the tenant was entitled to have received a 90 day notice to move pursuant to the Protecting Tenants at Foreclosure Act of 2009 (“PTFA”) § 702, 12 U.S.C. § 5220 (2009). The bank had held a Trustee’s Sale and provided the tenant living in the foreclosed property a 5 day notice. The Bank even waited 97 days before filing the eviction action. The Court of Appeals ruled the statute required a 90 day notice of termination of the tenant’s right of possession and nothing less satisfied the statute. The Court of Appeals also ruled that the trial court had erred in not dismissing the action for eviction. How about this, the tenant represented herself before the Court of Appeals and won!