On May 11, 2018 a
Request,Application
was filed
involving a dispute between
Alagria Eric,
Christina Alegria And Her Family Trust,
Pennymac Holdings Llc. Doe2,
Lee John,
Lee John As Trustee Of The 3432 Palo,
Ryu James Aka Huki Ryu,
and
Alagria Eric,
Christina Alegria And Her Family Trust,
David A. Spector Ceo Doe1,
Eric Alagria And Christina Alegria And Her Family Trust,
Jp Morgan Chase Bank Na,
Lemus Amy,
Lemuse Amy,
Matkin Rochellie,
Mtc Financial Inc. Dba Trustee Corps,
Pennymac Corp A Form Of Entity Unknown,
Pennymac Corp. A Form Of Entity Unknown,
Penny Mac Corp Doe3,
Pennymac Holdings Llc A Delaware Corporation,
Pennymac Holdings Llc. A Delaware Corporation,
Pennymac Holdings Llc. Doe2,
Pennymac Mortgage Investment Trust,
Pennymac Mortgage Investment Trust Holdings 1 Llc,
Pennymac Mortgage Investment Trust Holdings Llc.,
Quality Loan Services Corp.,
Quality Loan Services Corp. A California Corporation,
Trustee Corps Aka Mtc Financial Inc A California Corporation,
Trustee Corps Aka Mtc Financial Inc. A California Corporation,
Trustee Corp,
for civil
in the District Court of Los Angeles County.
Preview
ay
@
McCARTHY & HOLTHUS, LLP
Melissa Robbins Coutts, Esq. (SBN: 246723)
aS Matthew B: Learned, Esq. (SBN: 255499)
1770 Fourth Avenue
San Diego, CA 92101
Telephone: (619) 685-4800
FILED
Superior Court of Catifornia
County of Los Angeles
Facsimile: (619) 685-4811
Email: mlearned@mccarthyholthus.com JUL 19.2018
Lee
Attorneys for Defendant, she ri RK. 1per, cagcuttve iaicerrLlerk of Court
Quality Loan Service Corporation 8: , Deputy
“7G larietta Robinson
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10
il JOHN LEE AS TRUSTEE OF THE 3432 Case No. BC705825
PALO VISTA DRIVE TRUST,
12
REQUEST FOR JUDICIAL NOTICE IN
Plaintiff,
se SUPPORT OF DEMURRER TO
313
mse8
=2
vs.
COMPLAINT
ee
2214
ox=< <5 5 JP MORGAN CHASE BANK NA; QUALITY
mse! Date: August 27, 2018
ge LOAN SERVICE CORP; PENNYMAC
Bz. Time: 1:30 p.m.
215 MORTGAGE INVESTMENT TRUST Dept.: 3
HOLDINGS I LLC, MTC, A/K/A TRUSTEE Judge: Hon. Mare D. Gross
=e 216 CORP, and Does 1-20 inclusive,
mc 8
°17 Defendants.
18
19
20 Defendant Quality Loan Service Corporation (“Quality”) respectfully requests that
21 pursuant to California Evidence Code sections 451 and 452, this Court take judicial notice of all
22 documents on file in this matter, including but not limited to the pleadings and minutes therein.
23 Quality also requests this Court take judicial notice of the following lodged Exhibits,
24 pursuant to California Evidence Code section 452(h). These documents, which are recorded in
25 the Official Records of the County Recorder, are proper subjects of judicial notice. See. e.g.,
26 McElrov v. Chase Manhattan Mori. Co. (2005) 134 Cal.App.4th 388, 394; Evans v. Cal. Trailer
27 Court (1994) 28 Cal.App.4th 540, 549 (citing Maryland Casualty Co. v. Reeder (1990) 221
28 Cal.App.3d 961, 977). The existence of the documents can be readily determined by searching
1
REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO COMPLAINT
CA-18-832728-CV
Document Filed Date
July 19, 2018
Case Filing Date
May 11, 2018
Status
Default Judgment By Court - Before Trial 10/23/2020
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ay @ McCARTHY & HOLTHUS, LLP Melissa Robbins Coutts, Esq. (SBN: 246723) aS Matthew B: Learned, Esq. (SBN: 255499) 1770 Fourth Avenue San Diego, CA 92101 Telephone: (619) 685-4800 FILED Superior Court of Catifornia County of Los Angeles Facsimile: (619) 685-4811 Email: mlearned@mccarthyholthus.com JUL 19.2018 Lee Attorneys for Defendant, she ri RK. 1per, cagcuttve iaicerrLlerk of Court Quality Loan Service Corporation 8: , Deputy “7G larietta Robinson SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 il JOHN LEE AS TRUSTEE OF THE 3432 Case No. BC705825 PALO VISTA DRIVE TRUST, 12 REQUEST FOR JUDICIAL NOTICE IN Plaintiff, se SUPPORT OF DEMURRER TO 313 mse8 =2 vs. COMPLAINT ee 2214 ox=< <5 5 JP MORGAN CHASE BANK NA; QUALITY mse! Date: August 27, 2018 ge LOAN SERVICE CORP; PENNYMAC Bz. Time: 1:30 p.m. 215 MORTGAGE INVESTMENT TRUST Dept.: 3 HOLDINGS I LLC, MTC, A/K/A TRUSTEE Judge: Hon. Mare D. Gross =e 216 CORP, and Does 1-20 inclusive, mc 8 °17 Defendants. 18 19 20 Defendant Quality Loan Service Corporation (“Quality”) respectfully requests that 21 pursuant to California Evidence Code sections 451 and 452, this Court take judicial notice of all 22 documents on file in this matter, including but not limited to the pleadings and minutes therein. 23 Quality also requests this Court take judicial notice of the following lodged Exhibits, 24 pursuant to California Evidence Code section 452(h). These documents, which are recorded in 25 the Official Records of the County Recorder, are proper subjects of judicial notice. See. e.g., 26 McElrov v. Chase Manhattan Mori. Co. (2005) 134 Cal.App.4th 388, 394; Evans v. Cal. Trailer 27 Court (1994) 28 Cal.App.4th 540, 549 (citing Maryland Casualty Co. v. Reeder (1990) 221 28 Cal.App.3d 961, 977). The existence of the documents can be readily determined by searching 1 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO COMPLAINT CA-18-832728-CV