On April 30, 2019 a
Party Statement
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 L
1 AKERMAN LLP StJPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
PARISA JASSIM SBN 273915 SAI4 SERNARDlNO DISTRICT
2 Email parisa jassim@akerman com
ALEJANDRO PACHECO SBN 315136
3 Email alejandro pacheco@akerman com
4 2020
601 West Fifth Street Suite 300
4 Los Angeles California 90071
Y a
Telephone 213 688 9500
DA4SY AILON DEf UTY
j 5 Facsimile 213 627 6342
t1
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 CIVDS1913252
o M 12 Plaintiff Assigned to the Hon Janet M Frangie Dept
S29
13 v
a z DECLARATION OF ALEJANDRO P
14 WRIGHT FINLEY AND ZAK LLP PACHECO PURSUANT TO CODE OF
Q Q ATTORNEYS AT LAW and DOES 1 throu gh CIVIL PROCEDURE 430 41
a
s o 15 50 inclusive
ww Concurrently Filed
16 Defendants 1 Notice of Demurrer and Demurrer
2 Request for Judicial Notice
3
ooa 17
w Hearing Information
18 Date U 1 2 a7
Time 10 U Q W
19 Dept
S Zq
20
Complaint Filed Apri130 2019
21 Trial Date None
22
23 I Alejandro Pacheco declare as follows
24 1 I am licensed to practice law in the State of California and am an associate at the law
25 firm of Akerman LLP counsel of record for defendant JPMorgan Chase Bank N A Chase in this
26 matter I have personal knowledge of each fact stated in this declaration and if called to testify I could
27 and would competently testify to them
28
1 CASE NO CTVDS 1913252
DECLARATION OF ALEJANDRO PACHECO
52556102 1
1 2 I make this declaration under Code ofCivil Procedure 430 41 a 3 A in support of
2 Chase s demurrer to plaintiff Dr Denise Whisler s complaint
3 3 On February 27 2020 I sent Dr Whisler an e mail providing notice of the Court s
4 order that the parties meet and confer regarding her filing of an amended complaint I requested a
5
time to meet and confer Having not heard from Dr Whisler I also called her on February 27 February
6 28 March 2 and March 4 2020 but she did not answer
4 On March 6 2020 I sent a follow up e mail again requesting Dr Whisler s availability
g
to discuss the filing of an amended complaint Dr Whisler did not reply I also called Dr Whisler on
9
March 6 and March 13 2020 Dr Whisler did not answer
10
5 On March 20 25 and 26 2020 I sent additional e mails advising Dr Whisler that I
11
have been attempting to reach her by phone as well as by email to discuss her filing of an amended
o M 12
o complaint Dr Whisler did not reply I called Dr Whisler on March 27 2020 but she did not answer
M 13
a z 6 Dr Whisler has been nonresponsive to Chase s efforts to meet and confer regarding her
z W a w
14
filing of an amended complaint As such the parties have not reached an agreement resolving the
I
4 0 15
a objections raised by demurrer
Q 16
I declare under penalty ofperjury under the laws of the State of California the foregoing is true
3
o 17
w and correct
H
18
Executed May 1 2020 at Los Angeles California
19
20
21
Alejandro P Pacheco
22
23
24
25
26
27
28
2 CASE NO CiVDS1913252
DECLARATION OF ALEJANDRO PACHECO
52556102 1
Document Filed Date
May 04, 2020
Case Filing Date
April 30, 2019
Category
Unlimited Civil Complaint - Real Property
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Preview
E L 1 AKERMAN LLP StJPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO PARISA JASSIM SBN 273915 SAI4 SERNARDlNO DISTRICT 2 Email parisa jassim@akerman com ALEJANDRO PACHECO SBN 315136 3 Email alejandro pacheco@akerman com 4 2020 601 West Fifth Street Suite 300 4 Los Angeles California 90071 Y a Telephone 213 688 9500 DA4SY AILON DEf UTY j 5 Facsimile 213 627 6342 t1 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 CIVDS1913252 o M 12 Plaintiff Assigned to the Hon Janet M Frangie Dept S29 13 v a z DECLARATION OF ALEJANDRO P 14 WRIGHT FINLEY AND ZAK LLP PACHECO PURSUANT TO CODE OF Q Q ATTORNEYS AT LAW and DOES 1 throu gh CIVIL PROCEDURE 430 41 a s o 15 50 inclusive ww Concurrently Filed 16 Defendants 1 Notice of Demurrer and Demurrer 2 Request for Judicial Notice 3 ooa 17 w Hearing Information 18 Date U 1 2 a7 Time 10 U Q W 19 Dept S Zq 20 Complaint Filed Apri130 2019 21 Trial Date None 22 23 I Alejandro Pacheco declare as follows 24 1 I am licensed to practice law in the State of California and am an associate at the law 25 firm of Akerman LLP counsel of record for defendant JPMorgan Chase Bank N A Chase in this 26 matter I have personal knowledge of each fact stated in this declaration and if called to testify I could 27 and would competently testify to them 28 1 CASE NO CTVDS 1913252 DECLARATION OF ALEJANDRO PACHECO 52556102 1 1 2 I make this declaration under Code ofCivil Procedure 430 41 a 3 A in support of 2 Chase s demurrer to plaintiff Dr Denise Whisler s complaint 3 3 On February 27 2020 I sent Dr Whisler an e mail providing notice of the Court s 4 order that the parties meet and confer regarding her filing of an amended complaint I requested a 5 time to meet and confer Having not heard from Dr Whisler I also called her on February 27 February 6 28 March 2 and March 4 2020 but she did not answer 4 On March 6 2020 I sent a follow up e mail again requesting Dr Whisler s availability g to discuss the filing of an amended complaint Dr Whisler did not reply I also called Dr Whisler on 9 March 6 and March 13 2020 Dr Whisler did not answer 10 5 On March 20 25 and 26 2020 I sent additional e mails advising Dr Whisler that I 11 have been attempting to reach her by phone as well as by email to discuss her filing of an amended o M 12 o complaint Dr Whisler did not reply I called Dr Whisler on March 27 2020 but she did not answer M 13 a z 6 Dr Whisler has been nonresponsive to Chase s efforts to meet and confer regarding her z W a w 14 filing of an amended complaint As such the parties have not reached an agreement resolving the I 4 0 15 a objections raised by demurrer Q 16 I declare under penalty ofperjury under the laws of the State of California the foregoing is true 3 o 17 w and correct H 18 Executed May 1 2020 at Los Angeles California 19 20 21 Alejandro P Pacheco 22 23 24 25 26 27 28 2 CASE NO CiVDS1913252 DECLARATION OF ALEJANDRO PACHECO 52556102 1