On April 30, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Whisler, Denise,
and
Bohart, Bonnie,
Bohart, Randy,
Herring, Michele,
Jp Morgan Chase Bank, Na,
Jpmorgan Chase Bank, Na,
Mabudian, Mohsen,
Redfin Corporation,
Wright, Finlay And Zak Llp,
Wright, Finley And Zak, Llp Attorneys At Law,
for Unlimited Civil Complaint - Real Property
in the District Court of San Bernardino County.
Preview
E
1 AKERMAN LLP
A
PARISA JASSIM SBN 273915 CO UN YOF
SAN BERNARDINQ
2 Email parisaJassim c akerman com SAN BERRlAR INQ DISTRiGT
ALEJANDRO P PACHECO SBN 315136
3 Email alejandro pacheco c akerman com j 4 2020
601 West Fifth Street Suite 300
4 Los Angeles California 90071
r
Telephone 213 688 9500 aY
S Facsimile 213 627 6342 DAIS AtLON DEPUTY
i
6 Attorneys for Defendant
JPMORGAN CHASE BANK N A
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN BERNARDINO
10
11 DR DENISE WHISLER In Pro Per Case No CIVDS 1913252
o M 12 Plaintiff Assigned to the Hon Janet M Frangie Dept
o
wo N S29
13 v
a DEFENDANT JPMORGAN CHASE
z W 14 WRIGHT FINLEY AND ZAK LLP BANK N A S NOTICE OF DEMURRER
Q Qw ATTORNEYS AT LAW and DOES 1 through AND DEMURRER TO COMPLAINT
a
w
FW0
15 50 inclusive MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT THEREOF
Q h 16 Defendants
Concurrentl
3 V 17
o 1 Request for Judicial Notice
a
H 2 Declaration of Alejandro P Pacheco
1g
19 Hearing Information
Date 1 t
Time A 3 1
20
Dept S29
21
Complaint Filed Apri130 2019
Trial Date None
22
23
24
TO THE COURT ALL PARTIES AND THEIR ATTORNEYS OF RECORD
25 PLEASE TAKE NOTICE on v p DATE at t0 d TIME or as
j
26
soon thereafter as counsel may be heard in Department S29 of the San Bernardino Superior Court
27 located at 247 West 3rd Street San Bernardino California 92415 defendant JPMorgan Chase Bank
28
1 Case No CIVDS1913252
CHASE S NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT
szsvsz ri
1 N A
Chase will and hereby does demur to plaintiffDr Denise Whisler s complaint on the grounds
2 set forth herein
3 The demurrer bases on Code of Civil Procedure 430 10 e and and 430 50 a this notice
4 of demurrer the memorandum of points and authorities filed herewith all matters of which the court
5 may take judicial notice all pleadings records and files in this action and such evidence and argument
6 as may be presented at or before the hearing on this demurrer
7 DEMURRER TO ENTIRE COMPLAINT
8 Chase demurs generally and specially to plaintiff s entire complaint on the grounds the pleading
9 fails to state facts constituting a cause of action against it the pleading is uncertain and demurrer is
10 proper Code Civ Proc 430 10 e and and 430 50 a
11 DEMURRER TO WRONGFUL FORECLOSURE CAUSE OF ACTION
o M 12 Chase demurs generally and specially to plaintiffs cause of action for wrongful foreclosure on
o
MO
O N
13 the grounds it fails to state facts constituting a cause of action against Chase the pleading is uncertain
a
zW 14 and demurrer is proper Code Civ Proc 430 10 e and and 430 50 a
a x 15 WHEREFORE Chase prays for the following relief from this Court
16 1 That Chase s demurrer to plaintiffs complaint be sustained without leave to amend
a
o a 17 2 That Chase be dismissed from this action with prejudice
18 3 That Chase be awarded its fees and costs and
19 4 For such other relief as the Court deems just and proper
20
21 Dated May 1 2020 AKERMAN LLP
22
23 By
Parisa Jassim
24 Alejandro P Pacheco
Attorneys for Defendant
25
JPMORGAN CHASE BANK N A
26
27
28
2 Case No CIVDS 1913252
CHASE S NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT
52598277
Document Filed Date
May 04, 2020
Case Filing Date
April 30, 2019
Category
Unlimited Civil Complaint - Real Property
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
E 1 AKERMAN LLP A PARISA JASSIM SBN 273915 CO UN YOF SAN BERNARDINQ 2 Email parisaJassim c akerman com SAN BERRlAR INQ DISTRiGT ALEJANDRO P PACHECO SBN 315136 3 Email alejandro pacheco c akerman com j 4 2020 601 West Fifth Street Suite 300 4 Los Angeles California 90071 r Telephone 213 688 9500 aY S Facsimile 213 627 6342 DAIS AtLON DEPUTY i 6 Attorneys for Defendant JPMORGAN CHASE BANK N A 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO 10 11 DR DENISE WHISLER In Pro Per Case No CIVDS 1913252 o M 12 Plaintiff Assigned to the Hon Janet M Frangie Dept o wo N S29 13 v a DEFENDANT JPMORGAN CHASE z W 14 WRIGHT FINLEY AND ZAK LLP BANK N A S NOTICE OF DEMURRER Q Qw ATTORNEYS AT LAW and DOES 1 through AND DEMURRER TO COMPLAINT a w FW0 15 50 inclusive MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF Q h 16 Defendants Concurrentl 3 V 17 o 1 Request for Judicial Notice a H 2 Declaration of Alejandro P Pacheco 1g 19 Hearing Information Date 1 t Time A 3 1 20 Dept S29 21 Complaint Filed Apri130 2019 Trial Date None 22 23 24 TO THE COURT ALL PARTIES AND THEIR ATTORNEYS OF RECORD 25 PLEASE TAKE NOTICE on v p DATE at t0 d TIME or as j 26 soon thereafter as counsel may be heard in Department S29 of the San Bernardino Superior Court 27 located at 247 West 3rd Street San Bernardino California 92415 defendant JPMorgan Chase Bank 28 1 Case No CIVDS1913252 CHASE S NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT szsvsz ri 1 N A Chase will and hereby does demur to plaintiffDr Denise Whisler s complaint on the grounds 2 set forth herein 3 The demurrer bases on Code of Civil Procedure 430 10 e and and 430 50 a this notice 4 of demurrer the memorandum of points and authorities filed herewith all matters of which the court 5 may take judicial notice all pleadings records and files in this action and such evidence and argument 6 as may be presented at or before the hearing on this demurrer 7 DEMURRER TO ENTIRE COMPLAINT 8 Chase demurs generally and specially to plaintiff s entire complaint on the grounds the pleading 9 fails to state facts constituting a cause of action against it the pleading is uncertain and demurrer is 10 proper Code Civ Proc 430 10 e and and 430 50 a 11 DEMURRER TO WRONGFUL FORECLOSURE CAUSE OF ACTION o M 12 Chase demurs generally and specially to plaintiffs cause of action for wrongful foreclosure on o MO O N 13 the grounds it fails to state facts constituting a cause of action against Chase the pleading is uncertain a zW 14 and demurrer is proper Code Civ Proc 430 10 e and and 430 50 a a x 15 WHEREFORE Chase prays for the following relief from this Court 16 1 That Chase s demurrer to plaintiffs complaint be sustained without leave to amend a o a 17 2 That Chase be dismissed from this action with prejudice 18 3 That Chase be awarded its fees and costs and 19 4 For such other relief as the Court deems just and proper 20 21 Dated May 1 2020 AKERMAN LLP 22 23 By Parisa Jassim 24 Alejandro P Pacheco Attorneys for Defendant 25 JPMORGAN CHASE BANK N A 26 27 28 2 Case No CIVDS 1913252 CHASE S NOTICE OF DEMURRER AND DEMURRER TO COMPLAINT 52598277