On March 16, 2014 a
PLAINTIFFS' OPPOSITION TO MOTION FOR SUMMARY JUDGMENT
was filed
involving a dispute between
Center Street Lending Fund Iv Spe Llc,
De Jesus Raul,
Ortega Edwin,
and
Center Street Lending Corp.,
City Escrow,
Doe Oscar,
Dominguez Isidro Ernesto,
Duran Ulises,
First Equity Management Llc,
Foreclosure Services Inc. City Escrow,
Milan Investors Lp,
Pacific Coast Development Inc.,
Td Foreclosure Services Inc.,
for civil
in the District Court of Los Angeles County.
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e
LAW OFFICES OF SEVAG NIGOGHOSIAN
SEVAG NIGOGHOSIAN, SBN 224928
101 N. Brand Bivd., Suite 1970
Glendale, California 91203
Super; TE Bb
Telephone: (818) 956-1111 County op tn Calitornty
Facsimile: (818) 956-1983
Sherrip
HAR 0.7 2oyy
ae
Attorneys for Plaintiffs + Execute
Uitice, “C
RAUL DE JESUS and EDWIN ORTEGA lerk
hid! Cara » Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10
iM
RAUL DE JESUS and EDWIN ORTEGA ) CASE NO.: BCS78310 DIA
12
Plaintiffs, ) PLAINTIFFS’ OPPOSITION TO MOTION
13 } FOR SUMMARY JUDGMENT
VS.
4
TONY RAMIREZ, et al., and DOES 1-50
15 INCLUSIVE
16 Defendants.
17
AND ALL RELATED CROSS ACTIONS
18
19
20 I INTRODUCTION
2t Intervener, Center Street Lending Fund IV SPE, LLC’s (herein “INTERVENER”) Motion
22 for Summary Judgment should be denied because there are numerous triable issues of material
23 facts concerning INTERVENER’’s status as a bona fide encumbrancer, Specifically, there are
aw
24 disputed material facts concerning whether or not INTERVENER’s predecessor had actual
or
25 constructive notice of Plaintiffs’ interest in the subject property. Plaintiffs, RAUL DE JESUS
a and
ad 26 EDWIN ORTEGA, (PLAINTIFF)have
S" alleged in their First Amended Complaint and during
27 discovery that INTERVENER’s predecessor and several other Defendants were the alter ego's
of
28 each other and as such, had knowledge of agreements and clouds on title and were not a bona
fide
OPPOSITION TO MOTION FOR SUMMARY JUDGMENT 1
Document Filed Date
March 07, 2017
Case Filing Date
March 16, 2014
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e LAW OFFICES OF SEVAG NIGOGHOSIAN SEVAG NIGOGHOSIAN, SBN 224928 101 N. Brand Bivd., Suite 1970 Glendale, California 91203 Super; TE Bb Telephone: (818) 956-1111 County op tn Calitornty Facsimile: (818) 956-1983 Sherrip HAR 0.7 2oyy ae Attorneys for Plaintiffs + Execute Uitice, “C RAUL DE JESUS and EDWIN ORTEGA lerk hid! Cara » Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 iM RAUL DE JESUS and EDWIN ORTEGA ) CASE NO.: BCS78310 DIA 12 Plaintiffs, ) PLAINTIFFS’ OPPOSITION TO MOTION 13 } FOR SUMMARY JUDGMENT VS. 4 TONY RAMIREZ, et al., and DOES 1-50 15 INCLUSIVE 16 Defendants. 17 AND ALL RELATED CROSS ACTIONS 18 19 20 I INTRODUCTION 2t Intervener, Center Street Lending Fund IV SPE, LLC’s (herein “INTERVENER”) Motion 22 for Summary Judgment should be denied because there are numerous triable issues of material 23 facts concerning INTERVENER’’s status as a bona fide encumbrancer, Specifically, there are aw 24 disputed material facts concerning whether or not INTERVENER’s predecessor had actual or 25 constructive notice of Plaintiffs’ interest in the subject property. Plaintiffs, RAUL DE JESUS a and ad 26 EDWIN ORTEGA, (PLAINTIFF)have S" alleged in their First Amended Complaint and during 27 discovery that INTERVENER’s predecessor and several other Defendants were the alter ego's of 28 each other and as such, had knowledge of agreements and clouds on title and were not a bona fide OPPOSITION TO MOTION FOR SUMMARY JUDGMENT 1