Motion,Ex Parte: Surjit Bagga vs. City National Bank

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                                1    JEFFER MANGELS BUTLER & MITCHELL LLP
                  RICHARD A. ROGAN (Bar No. 67310)
             2    rrogan@jmbm.com                                  E-FILED
                  JOSHUA HAEVERNICK (Bar No. 308380)               11/3/2020 4:31 PM
             3    jhaevernick@jmbm.com                             Superior Court of California
                  Two Embarcadero Center, Fifth Floor              County of Fresno
             4    San Francisco, California 94111-3813             By: C. York, Deputy
                  Telephone:    (415) 398-8080
             5    Facsimile:    (415) 398-5584
             6    DOWLING AARON INCORPORATED
                  G. ANDREW SLATER (Bar No. 238126)
             7    aslater@dowlingaaron.com
                  8080 North Palm Avenue, Third Floor
             8    P.O. Box 28902
                  Fresno, California 93729-8902
             9    Telephone:     (559) 432-4500
                  Facsimile:     (559) 432-4590
             10
                  Attorneys for CITY NATIONAL BANK
             11

             12                     SUPERIOR COURT FOR THE STATE OF CALIFORNIA
             13                                    COUNTY OF FRESNO
             14   SURGIT BAGGA,                              CASE NO. 16CECG03336
             15               Plaintiff,
                                                             DECLARATION OF JOSHUA K.
             16         v.                                   HAEVERNICK IN SUPPORT OF MOTION
                                                             FOR SUMMARY JUDGMENT, OR IN THE
             17   CITY NATIONAL BANK, a national banking     ALTERNATIVE, MOTION FOR
                  association, et al.,                       SUMMARY ADJUDICATION
             18
                              Defendants.                    Date:    January 21, 2021
             19                                              Time:    3:30 p.m.
                                                             Dept.:   403
             20                                              Judge:   Hon. Kristi Culver Kapetan

             21                                              Complaint Filed:      October 10, 2016
                                                             Trial Date:           February 22, 2021
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                   DECLARATION
                  68480122v1     OF JOSHUA K. HAEVERNICK IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR
                                   IN THE ALTERNATIVE, MOTION FOR SUMMARY ADJUDICATION
             1            I, Joshua K. Haevernick, declare:

             2            1.      I am an attorney at law duly licensed to practice law before all of the courts of the

             3    State of California and am an associate with Jeffer Mangels Butler & Mitchell LLP, attorneys of

             4    record for Defendant City National Bank in the above entitled action. If called upon to testify to the

             5    matters set forth in this declaration, I could and would competently testify thereto as the facts herein

             6    set forth are personally known to me to be true.

             7            2.      On November 3, 2020, I performed a licensee search for Plaintiff Surjit (or Surgit)

             8    Bagga on the California Department of Real Estate website at: https://www.dre.ca.gov/. The search

             9    did not yield any results for either "Bagga, Surjit" or "Bagga, Surgit." True and correct copies of

             10   printouts from the searches are collectively attached hereto as Exhibit 1.

             11           3.      On November 3, 2020, I performed a Financial Services and Mortgage Lending

             12   Licensees search for Plaintiff Surjit (or Surgit) Bagga on the California Department of Financial

             13   Protections and Innovation at: https://dfpi.ca.gov/. The search did not yield any results for "Bagga."

             14   A true and correct copy of the printout from the search is attached hereto as Exhibit 2.

             15           I declare under penalty of perjury under the laws of the State of California that the foregoing

             16   is true and correct.

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             18   DATED: November 3, 2020

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                                                                         JOSHUA K. HAEVERNICK, Declarant
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                                                                     2
                   DECLARATION OF JOSHUA K. HAEVERNICK IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT, OR
                  68480122v1
                                 IN THE ALTERNATIVE, MOTION FOR SUMMARY ADJUDICATION