On June 16, 2015 a
Proof of Service
was filed
involving a dispute between
Eng, Martin,
and
Castellanos, Marylou,
Does 1 To 1000 Inclusive,
Jp Morgan Chase Bank, N.A.,
Lender Processing Services, Inc.,
Quality Loan Service Corporation Erroneously Sued,
Quality Loan Services,
Sotheby'S International Realty,
for civil
in the District Court of San Francisco County.
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BRYAN Cave LLP
THREE EMBARCADERO CENTER, 7" FLOOR
SAN FRANCISCO, CA 94111
Ce IN DH BR WN
NN NY NY YN NN DN Bee Be Be Be ew eB ee
oN DAA KB ONH SF SO HOH AAA KR wW HE S
BRYAN CAVE LLP
Daniel T..Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Three Embarcadero Center, 7" Floor
San Francisco, CA 94111
Telephone: (415) 675-3400
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com
goli.mahdavi@bryancave.com
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG, Case No. CGC-15-546377
Plaintiff,
PROOF OF SERVICE
ve
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Defendants.
[Filed concurrently with Notice of Motion,
Memorandum of Points and Authorities,
Declaration of Goli Mahdavi, and [Proposed]
Order
Date: July 10, 2017
Time: 9:00 a.m.
DEPT.: 302 - DISCOVERY
June 16, 2015
Complaint Filed:
Not Yet Assigned
Trial Date:
PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN CAVE LLP
THREE EMBARCADERO CENTER, 7” FLOOR
SAN FRANCISCO, CA 94111
Crm NY DW BRB BW NY
NN YN NY NN KY NY He Be ee Be eB eB eB eB
SCADA BF HH F&F SBD OA DA BF WHY HK OS
PROOF OF SERVICE
I am 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 Three Embarcadero Center,
T° Floor, San Francisco, CA 94111
On June 13, 2017, I caused to be served on the interested parties in said action the within:
NOTICE OF MOTION AND MOTION (1) FOR ORDER TO SHOW CAUSE
WHY CONTEMPT SANCTIONS SHOULD NOT ISSUE FOR THE FAILURE BY
PLAINTIFF TO PAY SANCTIONS; AND (2) REQUEST FOR MONETARY
SANCTIONS
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION
(1) FOR ORDER TO SHOW CAUSE WHY CONTEMPT SANCTIONS SHOULD
NOT ISSUE FOR THE FAILURE BY PLAINTIFF TO PAY SANCTIONS; AND
(2) REQUEST FOR MONETARY SANCTIONS
DECLARATION OF GOLI MAHDAVI IN SUPPORT OF MOTION (1) FOR
ORDER TO SHOW CAUSE WHY CONTEMPT SANCTIONS SHOULD NOT
ISSUE FOR THE FAILURE BY PLAINTIFF TO PAY SANCTIONS; AND (2)
REQUEST FOR MONETARY SANCTIONS
[PROPOSED] ORDER TO SHOW CAUSE RE: CONTEMPT AND SANCTIONS
by placing a true copy thereof in a sealed envelope(s) addressed to each as follows:
Michael J. McLaughlin Leticia Butler, Esq.
McLaughlin Yeh LLP McCarthy & Holthus, LLP
351 California Street, Suite 325 PSone
7 San Diego, CA 92101
San Francisco, CA 94104 Tel: (619) 685-4800
Phone: (415) 655-9753 Fax: (619) 685-4811
Fax: (415) 680-1701 Attorneys for Quality Loan Service Corp.
Attorney for Plaintiff Email: lbutler@mecarthyholthus.com
Email: mmclaughlin@mclaughlinyeh.com
[xx] BY FEDERAL EXPRESS - I caused the above-mentioned document(s) to be sent
via Federal Express overnight delivery. By placing a true and correct copy of such document(s)
enclosed in a sealed envelope or package designated by the express service carrier and deposited
ina facility regularly maintained by the express service carrier or delivered to a courier or driver
authorized to receive documents on its behalf, with delivery fees paid or provided for, addressed to
the address last shown by that person on any document filed in the action as indicated above.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on June 13, 2017, at San Francisco, California.
Kelly Feldman
254159.3\C0805 19\0386553 1
PROOF OF SERVICE ~ CASE NO, CGC-15-546377
Document Filed Date
June 13, 2017
Case Filing Date
June 16, 2015
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BRYAN Cave LLP THREE EMBARCADERO CENTER, 7" FLOOR SAN FRANCISCO, CA 94111 Ce IN DH BR WN NN NY NY YN NN DN Bee Be Be Be ew eB ee oN DAA KB ONH SF SO HOH AAA KR wW HE S BRYAN CAVE LLP Daniel T..Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Three Embarcadero Center, 7" Floor San Francisco, CA 94111 Telephone: (415) 675-3400 Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com goli.mahdavi@bryancave.com Attorneys for Defendant JPMORGAN CHASE BANK, N.A. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Case No. CGC-15-546377 Plaintiff, PROOF OF SERVICE ve JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Defendants. [Filed concurrently with Notice of Motion, Memorandum of Points and Authorities, Declaration of Goli Mahdavi, and [Proposed] Order Date: July 10, 2017 Time: 9:00 a.m. DEPT.: 302 - DISCOVERY June 16, 2015 Complaint Filed: Not Yet Assigned Trial Date: PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN CAVE LLP THREE EMBARCADERO CENTER, 7” FLOOR SAN FRANCISCO, CA 94111 Crm NY DW BRB BW NY NN YN NY NN KY NY He Be ee Be eB eB eB eB SCADA BF HH F&F SBD OA DA BF WHY HK OS PROOF OF SERVICE I am 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 Three Embarcadero Center, T° Floor, San Francisco, CA 94111 On June 13, 2017, I caused to be served on the interested parties in said action the within: NOTICE OF MOTION AND MOTION (1) FOR ORDER TO SHOW CAUSE WHY CONTEMPT SANCTIONS SHOULD NOT ISSUE FOR THE FAILURE BY PLAINTIFF TO PAY SANCTIONS; AND (2) REQUEST FOR MONETARY SANCTIONS MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION (1) FOR ORDER TO SHOW CAUSE WHY CONTEMPT SANCTIONS SHOULD NOT ISSUE FOR THE FAILURE BY PLAINTIFF TO PAY SANCTIONS; AND (2) REQUEST FOR MONETARY SANCTIONS DECLARATION OF GOLI MAHDAVI IN SUPPORT OF MOTION (1) FOR ORDER TO SHOW CAUSE WHY CONTEMPT SANCTIONS SHOULD NOT ISSUE FOR THE FAILURE BY PLAINTIFF TO PAY SANCTIONS; AND (2) REQUEST FOR MONETARY SANCTIONS [PROPOSED] ORDER TO SHOW CAUSE RE: CONTEMPT AND SANCTIONS by placing a true copy thereof in a sealed envelope(s) addressed to each as follows: Michael J. McLaughlin Leticia Butler, Esq. McLaughlin Yeh LLP McCarthy & Holthus, LLP 351 California Street, Suite 325 PSone 7 San Diego, CA 92101 San Francisco, CA 94104 Tel: (619) 685-4800 Phone: (415) 655-9753 Fax: (619) 685-4811 Fax: (415) 680-1701 Attorneys for Quality Loan Service Corp. Attorney for Plaintiff Email: lbutler@mecarthyholthus.com Email: mmclaughlin@mclaughlinyeh.com [xx] BY FEDERAL EXPRESS - I caused the above-mentioned document(s) to be sent via Federal Express overnight delivery. By placing a true and correct copy of such document(s) enclosed in a sealed envelope or package designated by the express service carrier and deposited ina facility regularly maintained by the express service carrier or delivered to a courier or driver authorized to receive documents on its behalf, with delivery fees paid or provided for, addressed to the address last shown by that person on any document filed in the action as indicated above. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on June 13, 2017, at San Francisco, California. Kelly Feldman 254159.3\C0805 19\0386553 1 PROOF OF SERVICE ~ CASE NO, CGC-15-546377