Party Notice: WHISLER-V-WRIGHT, FINLEY AND ZAK Print

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                                DR DENISE DEE WHISLER
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     3405 HIDALGO DRIVE
                                                                                     SUPER OR     ouR O CqLlFORNIA
                                                                                       COUNTY OF SAN BERNARD NO
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     SAN BERNARDINO CA 92404 2035                                                       SAN BERNAI DINO DISTRICT
     Cell       909 882 3655 Email drlwhisler@gmail     com
                                                                                            NOV 2 I 2019
 3   Plaintiff In Pro Per


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                                    SUPERIOR COURT OF CALIFORNIA                          ANIEL
                                                                                                           N EPUN
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                                     COUNTY OF SAN BERNARDINO


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     DR DENISE WHISLER In Pro Per              Case No           CIVDS 1913252


                        Plaintiff              MEMORANDUM OF POINTS                          AUTHORITIES BY

 8                                             DR DENISE WHISLER IN SUPPORT OF EXPARTE
                 vs                            MOTION FOR STAY OF JUDGEMENT AND

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                                               EXECUTIONS UNTIL RENDITION BY THE MOST
     WRIGHT FINLAY AND ZAK LLP                 HONORABLE COURT JUDGE FOR CASE NUMBER
lo   and    DOES 1 50 inclusive                CIVDS1913252
                                                1 STAY OF JLTDGEMENT FOR UD                        UDFS1902254

11                    Defendants                 A STAY OF EXECUTION OF EVICTION LOCKOUT
                                                      SCHEDULED FOR NOVEMBER 13 2019 6 Olam

12                                                    or any date thereafter before rendition of court case
                                                 B STAY OF UD PAYMENT OF 7 306 00
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                                               2 STAY OF EXECUTION OF ANY AND ALL
14                                               ACTIONS INCLUDING BUT NOT LIMITED TO
                                                  A     ANY SALE OF 1224 MAGNOLIA AVE
15                                                B     ANY SALE OF 1225 BROOKSIDE AVE
                                                  C     ANY SALE OR OTHERWISE OF ANY WHISLER

16                                                      PERSONAL BELONGINGS FURNITURE NATURE
                                                        PLANTS           ANIMALS

17                                                D     ANY TRESPASSING DAMAGING REMOVING
                                                        ANYTHI1vG FROM 1225 BROOKSIDE AVE WHICH
lg                                                      INCLUDES 1224 MAGNOLIA AVE


19                                             Related Case UDFS1902254


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                                               Defense           Civ Code     Section 2924
                                                                 Civ Code     Section 2924 subd a 1
21                                                               Code Civ     Proc Section 367
                                                                 California   Homeowner Bill of Rights enacted 2012
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                                               Complaint Filed           APRIL 30 2019
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                                               Date Friday I ovember 22 201
24                                             Time 8        6 am
                                              Dept           9

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     TO HONORABLE JUDGE OF THE SAN BERNARDINO COUNTY SUPERIOR COURT
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            1   Comes now Dr Denise Dee Whisler due to exigent circumstances which require immediate
2s


                                                         1
     CIVDS1913252     MEMORANDUM OF POINTS       AUTHORITIES BY DR DENISE WHISLER IN SUPPORT OF
     EXPARTE MOTION FOR STAY OF JUDGEMENT AND EXECUTIONS UNTIL RENDITION BY THE MOST
     HONORABLE COURT JUDGE FOR CASE NUMBER CIVDS1913252
                                                                               By Dr Denise Whisler 11 21 2019
y




    1   STAY actions to humble plead for Court Judgement in favor of Plaintiff


    2       2    Plaintiff is Dr Denise Dee Whisler

    s       3    Dr Denise Dee Whisler I am over the age of 18 have served two U S Federal tours as a

    9            Commissioned Officer     a California Veteran and I am a legal resident ofCalifornia


    s       4    I have a Doctor of Public Health degree in Health Promotion and Education with Doctoral

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                 Cognates in Epidemiology and Business Health Administration I am a research scientist

                 epidemiologist health professional and educator I love nature and the preservation of species

    s       5    My address is Dr Denise Whisler 3405 Hidalgo Dr San Bernardino CA 92404 2035

    9       6    The facts set forth herein are of my own personal knowledge and if sworn I could and

io      would competently testify thereto

il



i2                                                 INTRODUCTION


13          7    Plaintiff Dr Denise Whisler humbly submits her MEMORANDUM OF POINTS

i 4     AUTHORITIES BY DR DENISE WHISLER IN SUPPORT OF EXPARTE MOTION FOR STAY

i5      OF JUDGEMENT AND EXECUTIONS UNTIL RENDITION BY THE MOST HONORABLE

i 6     COURT JUDGE FOR CASE NUMBER CIVDS19132528

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                 8 Dr Whisler had posted at her 1225 Brookside Ave Redlands CA 92373 property which
i s     includes 1224 Magnolia Ave a lockout notice for November 13 2019 This is an extremelv exigent

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        circumstance which requires a Court Stay of Judgement to prevent the Lockout of Dr Whisler from her
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        retirement home and property still containing her and her sisters personal belongings furniture and

2i      nature   plants and animals



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                 9 Please note that there are two Deeds for the same property of 1224 Magnolia Ave Redlands
23      CA 92373 FACT Dr Whisler s 2005 Titled Deed for 1225 Brookside Ave Redlands CA 92373

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        includes her 1224 Magnolia Ave property which includes her retirement home FACT CHASE s 2019

2s      deed does not have title for 1224 Magnolia Ave CHASE s 2019 deed is invalid void

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                 10 Please also note that the first mortgage for 1224 Magnolia Ave was paid offl with zero

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        balance in December 2017 SETERUS failed to file a DEED of FULL RECONVEYANCE

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        CIVDS1913252   MEMORANDUM OF POINTS           AUTHORITIES BY DR DENISE WHISLER IN SUPPORT OF
        EXPARTE MOTION FOR STAY OF JUDGEMENT AND EXECUTIONS UNTIL RENDITION BY THE MOST
        HONORABLE COURT JiJDGE FOR CASE NUMBER CIVDS1913252               By Dr Denise Whisler 11 21 2019