pursuant to a ‘power of sale provision contained in any deed of trust’ ”) (quoting Leake, 798 F.Supp.2d at 256). Second, Duffy alleges that there was a violation of D.C. Code § 47-1431 when the Note was sold in September of 2011 without being recorded. Compl. ¶¶ 13-14. There is no requirement that an assignment of a note be recorded to be valid. See Robinson v. Deutsche Bank Nat'l Trust Co., 932 F.Supp.2d 95, 104 (D.D.C.2013) (noting that “District of Columbia law does not require an assignment of a note or deed of trust to be recorded in order for the transfer to be valid”); Leake, 798 F.Supp.2d at 257 (concluding that bank could enforce note’s foreclosure provision under District of Columbia law, despite its failure to record the assignment of the note); Diaby, 795 F.Supp.2d at 112 (<HOLDING>). Thus, Duffy’s argument regarding the failure
holding that failure to record an assignment does not give rise to a cause of action holding that possessing property of another for the purpose of security on a debt does not give rise to probable cause to arrest holding that a dispute regarding payment of a restaurant bill does not give rise to probable cause to arrest holding that the first amendment does not by itself give rise to a cause of action for damages holding that an employers mere failure to follow its own rules and regulations does not give rise to a protected property interest