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 06/20/2022 04:14 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Parenteau,Deputy Clerk



                              1     MICHAEL W. VIVO LI (Bar No. 184366)
                                    JASON P. SACCUZZO (Bar No. 221837)
                             2      VIVOLI SACCUZZO, LLP
                                    3104 Fourth Avenue
                             3      San Diego, California 92103
                                    (619) 744-9992 (Tel)
                             4      (619) 744-9994 (Fax)
                             5      Attorneys for Plaintiffs,
                                    SHAHRAM JEFF JAVIDZAD, as Co-Trustee of the
                             6      JM JA VIDZAD 2008 TRUST DATED SEPTEMBER 18, 2008
                                    and MONICA NO URMAN JAVIDZAD, Co-Trustee of the
                             7      JM JA VIDZAD 2008 TRUST DATED SEPTEMBER 18, 2008
                             8                                   SUPERIOR COURT OF THE STATE OF CALIFORNIA
                             9                           COUNTY OF LOS ANGELES - WESTERN JUDICIAL DISTRICT
                            10
                            11       SHAHRAM JEFF JA VIDZAD, as Co-Trustee                                      )   CASE NO.: 20SMCV01076
                                     of the JM JA VIDZAD 2008 TRUST DATED                                       )   [Assigned for All Purposes to Hon. Craig D.
                            12       SEPTEMBER 18, 2008; and MONICA                                             )   Karlan, Dept. N]
                                     NO URMAN JA VIDZAD, as Co-Trustee of the                                   )
                            13       JM JAVIDZAD 2008 TRUST DATED                                               )
                                     SEPTEMBER 18, 2008;                                                        )   DECLARATION OF SHAHRAM JEFF
                            14                                                                                      JA VIDZAD IN SUPPORT OF
                                                          Plaintiffs,              )                                PLAINTIFFS' MOTION FOR
                            15                                                     )                                SUMMARY ADJUDICATION OF
                                         V.                                        )                                THEIR FOURTH CAUSE OF ACTION
                            16
                                                                                   )                                TO SET ASIDE FORECLOSURE SALE
                            17       SPROUT MORTGAGE CORPORATION, a                )
                                     Delaware corporation; PRESTIGE DEFAULT
                            18       SERVICES, LLC, a California limited liability ) Date:                                                 TBD
                                     company; SPROUT LENDING, LLC, a                )                               Time:
                            19       Delaware limited liability company; FAY        )                               Dept:                  N
                                     SERVICING, an entity of unknown form and )
                           20        citizenship; and DOES 1 through 75, inclusive, )                               Complaint Filed: August 10, 2020
                                                                                    )                               SAC Filed:       November 15, 2021
                           21                      Defendants.
                           22
                                    _______________                                 )
                                                                                    )
                                                                                                                    Trial Date:      May 8, 2023


                           23                  I, SHAHRAM JEFF JA VIDZAD, declare as follows:
                           24                   I.         I am over the age of eighteen and am one of the Plaintiffs herein. I am also a Co-
                           25       Trustee of the JM Javidzad 2008 Trust dated September 18, 2008, which claims to hold superior
                           26       title to the real property that is the subject of this action. My wife, Monica Nourman Javidzad, is
                           27       also a Co-Trustee of the same trust, but was not a named borrower on the loan at issue in this
                           28       case held by Sprout Mortgage Corporation ("Sprout Corp"). I have personal knowledge of all



                                         DECLARATION OF SHAHRAM JEFF JAVIDZAD IN SUPPORT OF MOTION FOR SUMMARY ADJUDICATION