On June 16, 2015 a
Party Discovery
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.
Preview
BRYAN Cave LLP,
THREE EM@ARCADERO CENTER, 77 FLOOR
SAN FRANCISCO, CA 94111
oo OND HW BR WN
BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Three Embarcadero Center, 7" Floor
San Francisco, CA 941111
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.
ELECTRONICALLY
FILED
‘Superior Court of Caltfornia,
‘County of San Francisco
01/04/2017
Clerk of the Court
BY:MADONNA CARANTO
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG,
Plaintiff,
Vv.
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Defendants.
Case No. CGC-15-546377
PROOF OF SERVICE
Complaint Filed:
Trial Date:
June 16, 2015
Not Yet Assigned
PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN Cave LLP,
THREE EMBARCADERO CENTER, 7™
FLOOR
SAN FRANCISCO, CA 94111
oo OND HW BR WN
PROOF OF SERVICE
1 am employed in the City and County of San Francisco, State of California. | am over the
age of 18 and not a party to the within action. My business address is Three Embarcadero Center,
7" Floor, San Francisco, CA 94111
On January 4, 2017, I caused to be served on the interested parties in said action the
within:
NOTICE OF MOTION AND MOTION TO HAVE REQUESTS FOR
ADMISSIONS DEEMED ADMITTED, TO COMPEL DISCOVERY RESPONSES
AND THE PRODUCTION OF DOCUMENTS AND TO IMPOSE SANCTIONS,
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION
TO HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO
COMPEL DISCOVERY RESPONSES AND THE PRODUCTION OF
DOCUMENTS AND TO IMPOSE SANCTIONS
DECLARATION OF GOLI MAHDAVI IN SUPPORT OF MOTION TO HAVE
REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO COMPEL
DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND
TO IMPOSE SANCTIONS
[PROPOSED] ORDER TO DEEM REQUESTS FOR ADMISSIONS ADMITTED,
COMPELLING DISCOVERY RESPONSES AND THE PRODUCTION OF
DOCUMENTS AND IMPOSING SANCTIONS
by placing a true copy thereof in a sealed envelope(s) addressed to each as follows:
Peter L. Kutrubes, Esq.
Law Offices of Peter L. Kutrubes & Associates, PC, Inc.
590 Lennon Lane, Suite 180
Walnut Creek, CA 94598
Tel: 925.939.9600 Ext. 101
Fax: 925.256.7660
Attorney for Plaintiff
Email: pkutrubes@kutrubeslaw.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
in a 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.
Leticia “Tia”Butler, Esq. Stanley W. Smith
McCarthy & Holthus, LLP Niven & Smith
1770 4" Avenue 555 Montgomery Street, Suite 1750
San Diego, CA 92101 San Francisco, CA 94111-2517
Tel: (619) 685-4800 Tel: (415) 981-5451
Fax: (619) 685-4811 Fax: (415) 433-5439
Attorneys for Quality Loan Service Corp. Attorneys for Sotheby's International Realty,
Email: Ibuter@mccarthyholtus.com Inc. & Mary Lou Castellanos
Email: sws@nivensmith.com
254159.2\CO80519\0386553 1
PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN Cave LLP,
THREE EMBARCADERO CENTER, 7™
FLOOR
SAN FRANCISCO, CA 94111
oo OND HW BR WN
[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.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on January 4, 2017, at San Francisco, California.
& of 4— a
“O>
Kelly Feldman
254159.2\CO80519\0386553 2
PROOF OF SERVICE — CASE NO. CGC-15-546377
Preview
BRYAN Cave LLP, THREE EM@ARCADERO CENTER, 77 FLOOR SAN FRANCISCO, CA 94111 oo OND HW BR WN BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Three Embarcadero Center, 7" Floor San Francisco, CA 941111 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. ELECTRONICALLY FILED ‘Superior Court of Caltfornia, ‘County of San Francisco 01/04/2017 Clerk of the Court BY:MADONNA CARANTO Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Plaintiff, Vv. JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Defendants. Case No. CGC-15-546377 PROOF OF SERVICE Complaint Filed: Trial Date: June 16, 2015 Not Yet Assigned PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN Cave LLP, THREE EMBARCADERO CENTER, 7™ FLOOR SAN FRANCISCO, CA 94111 oo OND HW BR WN PROOF OF SERVICE 1 am employed in the City and County of San Francisco, State of California. | am over the age of 18 and not a party to the within action. My business address is Three Embarcadero Center, 7" Floor, San Francisco, CA 94111 On January 4, 2017, I caused to be served on the interested parties in said action the within: NOTICE OF MOTION AND MOTION TO HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO COMPEL DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND TO IMPOSE SANCTIONS, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO COMPEL DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND TO IMPOSE SANCTIONS DECLARATION OF GOLI MAHDAVI IN SUPPORT OF MOTION TO HAVE REQUESTS FOR ADMISSIONS DEEMED ADMITTED, TO COMPEL DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND TO IMPOSE SANCTIONS [PROPOSED] ORDER TO DEEM REQUESTS FOR ADMISSIONS ADMITTED, COMPELLING DISCOVERY RESPONSES AND THE PRODUCTION OF DOCUMENTS AND IMPOSING SANCTIONS by placing a true copy thereof in a sealed envelope(s) addressed to each as follows: Peter L. Kutrubes, Esq. Law Offices of Peter L. Kutrubes & Associates, PC, Inc. 590 Lennon Lane, Suite 180 Walnut Creek, CA 94598 Tel: 925.939.9600 Ext. 101 Fax: 925.256.7660 Attorney for Plaintiff Email: pkutrubes@kutrubeslaw.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 in a 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. Leticia “Tia”Butler, Esq. Stanley W. Smith McCarthy & Holthus, LLP Niven & Smith 1770 4" Avenue 555 Montgomery Street, Suite 1750 San Diego, CA 92101 San Francisco, CA 94111-2517 Tel: (619) 685-4800 Tel: (415) 981-5451 Fax: (619) 685-4811 Fax: (415) 433-5439 Attorneys for Quality Loan Service Corp. Attorneys for Sotheby's International Realty, Email: Ibuter@mccarthyholtus.com Inc. & Mary Lou Castellanos Email: sws@nivensmith.com 254159.2\CO80519\0386553 1 PROOF OF SERVICE — CASE NO. CGC-15-546377BRYAN Cave LLP, THREE EMBARCADERO CENTER, 7™ FLOOR SAN FRANCISCO, CA 94111 oo OND HW BR WN [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. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on January 4, 2017, at San Francisco, California. & of 4— a “O> Kelly Feldman 254159.2\CO80519\0386553 2 PROOF OF SERVICE — CASE NO. CGC-15-546377