Motion-Secondary: SHAHRAM JEFF JAVIDZAD VS SPROUT MORTGAGE CORPORATION., ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/14/2022 07:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Kulkin,Deputy Clerk



                1     WRIGHT, FINLAY & ZAK, LLP
                      T. Robert Finlay, Esq., SBN 167280
                2     Kristina M. Pelletier, Esq., SBN 279533
                3     4665 MacArthur Court, Suite 200
                      Newport Beach, CA 92660
                4     Tel: (949) 477-5050; Fax: (949) 608-9142
                      kpelletier@wrightlegal.net
                5
                      Attorneys for Defendants,
                6     SPROUT MORTGAGE CORPORATION; SPROUT LENDING, LLC; FAY SERVICING, LLC
                      (erroneously sued herein as FAY SERVICING); and PRESTIGE DEFAULT SERVICES, LLC
                7
                8                                                     SUPERIOR COURT OF CALIFORNIA

                9                              COUNTY OF LOS ANGELES - WESTERN JUDICIAL DISTRICT

              10
                      SHAHRAM JEFF JAVIDZAD, as Co-Trustee                                            Case No.: 20SMCV01076
              11
                      of the JM JAVIDZAD 2008 TRUST DATED
              12      SEPTEMBER 18, 2008; and MONICA                                                  Assigned to Hon. Craig D. Karlan, Dept. N
                      NOURMAN JAVIDZAD, as Co-Trustee of the
              13      JM JAVIDZAD 2008 TRUST DATED                                                    DEFENDANTS' REPLY IN SUPPORT OF
                      SEPTEMBER 18, 2008,                                                             DEMURRER TO PLAINTIFFS' SECOND
              14
                                                                                                      AMENDED COMPLAINT
              15                              Plaintiffs,
                                  vs.
              16
                                                                                                      Hearing on Demurrer:
                      SPROUT MORTGAGE CORPORATION, a
              17      Delaware corporation; PRESTIGE DEFAULT                                          Date: July 21, 2022
                      SERVICES, LLC, a California limited liability                                   Time: 8:30 a.m.
              18      company; SPROUT LENDING, LLC, a                                                 Dept.: N
                      Delaware limited liability company; FAY
              19      SERVICING, an entity of unknown form and                                        Complaint filed: August 10, 2020
                      citizenship; and DOES 1 through 75, inclusive,                                  FAC filed:       October 19, 2020
              20
                                                                                                      SAC filed:       November 15, 2021
              21                              Defendants.

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              23                  TO THIS HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF

              24      RECORD, IF ANY:
              25                  PLEASE TAKE NOTICE that Defendants SPROUT MORTGAGE CORPORATION,
              26      SPROUT LENDING, LLC, FAY SERVICING, LLC (erroneously sued herein as FAY SERVICING)

              27      ("Fay") and PRESTIGE DEFAULT SERVICES, LLC ("Prestige") (collectively" Defendants") hereby
              28      submit this Memorandum of Points and Authorities in response to the Opposition of Plaintiffs

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                               DEFENDANTS' REPLY IN SUPPORT OF DEMURRER TO SECOND AMENDED COMPLAINT