On June 16, 2015 a
DECLARATION OF GOLI MAHDAVI PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE SECTION 430.41 (TRANSACTION ID # 16048038) FILED BY DEFENDANT JP MORGAN CHASE BANK, N.A.
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
§60 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94105-2994
Cm NIN DWH FF WN |
RN NN NY NN NNN HY ewe we ee we we ew
oN DAU KF BH KF STO we NIN DU BF WN HK SC
BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No, 245705 ELECTRONICALLY
560 Mission Street, 25th Floor FILED
San Francisco, CA 94105-2994 Fipleedot eect
Telephone: (415) 675-3400 Caduty bi aun Pidacaecolt
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com 02/18/2016
golimahdavi@bryancave.com BY:ROMY RISK
7 Deputy Clerk
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,
DECLARATION OF GOLI MAHDAVI
v. PURSUANT TO CALIFORNIA CODE OF
CIVIL PROCEDURE SECTION
JPMORGAN CHASE BANK, N.A.; 430.41
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive, [Filed concurrently with Notice of Demurrer
and Demurrer; Request for Judicial Notice;
Defendants. and (Proposed) Order]
Date: March 21, 2016
Time: 9:30 a.m.
Dept.: 501
Complaint Filed: June 16, 2015
Trial Date: Not Yet Assigned
SFO1DOCS\272266.1
DECLARATION OF GOLI MAHDAVISO me NIN DH BR WN
BRYAN Cave LLP
S60 MISSION STREET, 25TH FLOOR
SAN FRANCISCO, CA 94705-2994
DECLARATION OF GOLI MAHDAVI
I, Goli Mahdavi, declare as follows:
1. I am an attorney admitted to practice before this Court with the law firm Bryan
Cave LLP, counsel of record for Defendant JPMorgan Chase Bank, N.A. (“Chase”). I have
personal knowledge of the matters set forth herein, and if called upon to do so, could and would
testify competently to them. I make this declaration pursuant to California Code of Civil
Procedure §430.41.
2. On February 16, 2016, I called Plaintiffs counsel and was advised that he was
unavailable, | left a voice message asking for a return call to meet and confer regarding Plaintiff's
amended complaint.
3. On February 17, 2016, I called Plaintiffs counsel and was advised that he was
unavailable. I left a voice message asking for a return call to meet and confer regarding Plaintiff's
amended complaint. Plaintiff’s counsel returned my call that day. We discussed my client’s
arguments raised on demurrer to the original complaint and the new arguments to be raised on
demurrer to the amended complaint. We were not able to reach any solution regarding the
objections raised by my client. We also discussed Plaintiff's prior settlement offer and my client’s
rejection of the same.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this 18th day of February 26 an Francisco, California.
Goli Mahdavi-——
SFOIDOCS\272266.1 1
DECLARATION OF GOLI MAHDAVI
Document Filed Date
February 18, 2016
Case Filing Date
June 16, 2015
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BRYAN Cave LLP §60 MISSION STREET, 25TH FLOOR SAN FRANCISCO, CA 94105-2994 Cm NIN DWH FF WN | RN NN NY NN NNN HY ewe we ee we we ew oN DAU KF BH KF STO we NIN DU BF WN HK SC BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No, 245705 ELECTRONICALLY 560 Mission Street, 25th Floor FILED San Francisco, CA 94105-2994 Fipleedot eect Telephone: (415) 675-3400 Caduty bi aun Pidacaecolt Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com 02/18/2016 golimahdavi@bryancave.com BY:ROMY RISK 7 Deputy Clerk 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, DECLARATION OF GOLI MAHDAVI v. PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE SECTION JPMORGAN CHASE BANK, N.A.; 430.41 QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, [Filed concurrently with Notice of Demurrer and Demurrer; Request for Judicial Notice; Defendants. and (Proposed) Order] Date: March 21, 2016 Time: 9:30 a.m. Dept.: 501 Complaint Filed: June 16, 2015 Trial Date: Not Yet Assigned SFO1DOCS\272266.1 DECLARATION OF GOLI MAHDAVISO me NIN DH BR WN BRYAN Cave LLP S60 MISSION STREET, 25TH FLOOR SAN FRANCISCO, CA 94705-2994 DECLARATION OF GOLI MAHDAVI I, Goli Mahdavi, declare as follows: 1. I am an attorney admitted to practice before this Court with the law firm Bryan Cave LLP, counsel of record for Defendant JPMorgan Chase Bank, N.A. (“Chase”). I have personal knowledge of the matters set forth herein, and if called upon to do so, could and would testify competently to them. I make this declaration pursuant to California Code of Civil Procedure §430.41. 2. On February 16, 2016, I called Plaintiffs counsel and was advised that he was unavailable, | left a voice message asking for a return call to meet and confer regarding Plaintiff's amended complaint. 3. On February 17, 2016, I called Plaintiffs counsel and was advised that he was unavailable. I left a voice message asking for a return call to meet and confer regarding Plaintiff's amended complaint. Plaintiff’s counsel returned my call that day. We discussed my client’s arguments raised on demurrer to the original complaint and the new arguments to be raised on demurrer to the amended complaint. We were not able to reach any solution regarding the objections raised by my client. We also discussed Plaintiff's prior settlement offer and my client’s rejection of the same. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 18th day of February 26 an Francisco, California. Goli Mahdavi-—— SFOIDOCS\272266.1 1 DECLARATION OF GOLI MAHDAVI