Preview
Co em ND nA BF WN
Seo Be ee
Ww NY KF SCS
BRYAN CAVE LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994
NN YN YN NN YN SF SF KF Be
ety DAA HH KF SoC we NI DYN
BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Chase Haslam, California Bar No. 304965
560 Mission Street, 25th Floor
San Francisco, CA 94105-2994
Telephone: (415) 675-3400
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com
golimahdavi@bryancave,com
chase. haslam@bryancave.com
Attomeys for Defendant
JPMORGAN CHASE BANK, N.A.
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
07/29/2016
Clerk of the Court
BY:DAVID YUEN
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG,
Plaintiff,
v.
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER.
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Defendants.
283729
Case No. CGC-15-546377
AMENDED NOTICE OF MOTION FOR
JUDGMENT ON THE PLEADINGS OF
DEFENDANT JPMORGAN CHASE
BANK,N.A,
[previously filed with Notice of Motion,
Request for Judicial Notice and [Proposed]
Order]
Date: September 9, 2016
Time: 9:30 a.m.
Dept.: 302
RES ID: 07140812-04
June 16, 2015
Complaint Filed:
Not Yet Assigned
Trial Date:
AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGSoem N DH BF WHY
Soe ee
F wWNH FE
BRYAN CAVE LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994
NY NY bY NY NY N NY NY NY HS Se Ee Se eH
CcAXQ DA KB HH KH SO HM AK AA
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORDS:
PLEASE TAKE NOTICE that the Motion for Judgment on the Pleadings of Defendant
JPMorgan Chase Bank, N.A., previously noticed for hearing on August 12, 2016, is now set for
September 9, 2016, or as soon thereafter as the matter may be heard in Department 302 of the
above-referenced court located at 400 McAllister Street, San Francisco, California 94102.
BRYAN CAVE LLP
Daniel Rockey
Goli Mahdavi
Chase Has
Dated: July 29, 2016
By:
Goli Mahdavi
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
283729 1
AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGS,=
PROOF OF SERVICE
Iam employed in the City and County of San Francisco, State of California. I am over the
age of 18 and not a party to the within action. My business address is 560 Mission, 25th Floor,
San Francisco, CA 94105.
On July 29, 2016, I caused to be served on the interested parties in said action the within:
AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGS OF
DEFENDANT JPMORGAN CHASE BANK, N.A.
by placing a true copy thereof in a sealed envelope(s) addressed to each as follows:
Joseph L. DeClue, Esq. Leticia “Tia’Butler, Esq.
SO MeN DH BF WD
De Clue Law Grou
2372 SE Bristol Street, 2" Floor
Newport Beach, CA 92660
Tel: (949) 596-7145
Fax: (949) 258-5899
Attorneys for Plaintiff
McCarthy & Holthus, LLP
1770 4" Avenue
San Diego, CA 92101
Tel: (619) 685-4800
Fax: (619) 685-4811
Attorneys for Quality Loan Service Corp.
joe@decluelawgroup.com Ibutler&mecarthyholthus.com
BRYAN Cave LLP
560 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA’ 94105-2994
Stanley W. Smith
Leo M. LaRocca
Niven & smith
555 Montgomery Street, Suite 1750
San Francisco, CA 94111-2517
Tel: (415) 981-5451
Fax: (415) 433-5439
Attorneys for Sotheby’s International Realty
[XX ] BY MAIL [am “readily familiar” with the firm’s practice of collection and
processing correspondence for mailing. Under that practice it would be deposited with
U.S. Postal Service on that same day with postage thereon fully prepaid at San Francisco,
California in the ordinary course of business. I am aware that on motion of the party
served, service is presumed invalid if postal cancellation date or postage meter date is
more than one day after date of deposit for mailing in affidavit.
[] BY FACSIMILE: I communicated the above-mentioned document(s) via
facsimile to the addressee as indicated above. The transmission was reported complete and
without error by a transmission report issued by the facsimile transmission machine as defined in
California Rule of Court 2003 upon which the said transmission was made immediately following
the transmission. A true and correct copy of the transmittal report bearing the date, time and
sending facsimile machine telephone number shall be attached to the original proof of service.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on July 29, 2016, at San Francisees Californs :
Cd AV
Robert L Novak
254159.1\CO80519\0386553 1
PROOF OF SERVICE — CASE NO. CGC-15-546377
Preview
Co em ND nA BF WN Seo Be ee Ww NY KF SCS BRYAN CAVE LLP 560 MISSION STREET, 25TH FLOOR SAN FRANCISCO, CA 94105-2994 NN YN YN NN YN SF SF KF Be ety DAA HH KF SoC we NI DYN BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Chase Haslam, California Bar No. 304965 560 Mission Street, 25th Floor San Francisco, CA 94105-2994 Telephone: (415) 675-3400 Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com golimahdavi@bryancave,com chase. haslam@bryancave.com Attomeys for Defendant JPMORGAN CHASE BANK, N.A. ELECTRONICALLY FILED Superior Court of California, County of San Francisco 07/29/2016 Clerk of the Court BY:DAVID YUEN Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Plaintiff, v. JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER. PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Defendants. 283729 Case No. CGC-15-546377 AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGS OF DEFENDANT JPMORGAN CHASE BANK,N.A, [previously filed with Notice of Motion, Request for Judicial Notice and [Proposed] Order] Date: September 9, 2016 Time: 9:30 a.m. Dept.: 302 RES ID: 07140812-04 June 16, 2015 Complaint Filed: Not Yet Assigned Trial Date: AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGSoem N DH BF WHY Soe ee F wWNH FE BRYAN CAVE LLP 560 MISSION STREET, 25TH FLOOR SAN FRANCISCO, CA 94105-2994 NY NY bY NY NY N NY NY NY HS Se Ee Se eH CcAXQ DA KB HH KH SO HM AK AA TO ALL PARTIES AND THEIR ATTORNEYS OF RECORDS: PLEASE TAKE NOTICE that the Motion for Judgment on the Pleadings of Defendant JPMorgan Chase Bank, N.A., previously noticed for hearing on August 12, 2016, is now set for September 9, 2016, or as soon thereafter as the matter may be heard in Department 302 of the above-referenced court located at 400 McAllister Street, San Francisco, California 94102. BRYAN CAVE LLP Daniel Rockey Goli Mahdavi Chase Has Dated: July 29, 2016 By: Goli Mahdavi Attorneys for Defendant JPMORGAN CHASE BANK, N.A. 283729 1 AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGS,= PROOF OF SERVICE Iam employed in the City and County of San Francisco, State of California. I am over the age of 18 and not a party to the within action. My business address is 560 Mission, 25th Floor, San Francisco, CA 94105. On July 29, 2016, I caused to be served on the interested parties in said action the within: AMENDED NOTICE OF MOTION FOR JUDGMENT ON THE PLEADINGS OF DEFENDANT JPMORGAN CHASE BANK, N.A. by placing a true copy thereof in a sealed envelope(s) addressed to each as follows: Joseph L. DeClue, Esq. Leticia “Tia’Butler, Esq. SO MeN DH BF WD De Clue Law Grou 2372 SE Bristol Street, 2" Floor Newport Beach, CA 92660 Tel: (949) 596-7145 Fax: (949) 258-5899 Attorneys for Plaintiff McCarthy & Holthus, LLP 1770 4" Avenue San Diego, CA 92101 Tel: (619) 685-4800 Fax: (619) 685-4811 Attorneys for Quality Loan Service Corp. joe@decluelawgroup.com Ibutler&mecarthyholthus.com BRYAN Cave LLP 560 MISSION STREET, 25TH FLOOR SAN FRANCISCO, CA’ 94105-2994 Stanley W. Smith Leo M. LaRocca Niven & smith 555 Montgomery Street, Suite 1750 San Francisco, CA 94111-2517 Tel: (415) 981-5451 Fax: (415) 433-5439 Attorneys for Sotheby’s International Realty [XX ] BY MAIL [am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. Postal Service on that same day with postage thereon fully prepaid at San Francisco, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [] BY FACSIMILE: I communicated the above-mentioned document(s) via facsimile to the addressee as indicated above. The transmission was reported complete and without error by a transmission report issued by the facsimile transmission machine as defined in California Rule of Court 2003 upon which the said transmission was made immediately following the transmission. A true and correct copy of the transmittal report bearing the date, time and sending facsimile machine telephone number shall be attached to the original proof of service. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on July 29, 2016, at San Francisees Californs : Cd AV Robert L Novak 254159.1\CO80519\0386553 1 PROOF OF SERVICE — CASE NO. CGC-15-546377