On August 10, 2021 a
A USREC Anti-SLAPP Schwartz Dec01
was filed
involving a dispute between
Neel, Jason,
Rushmyfile, Inc.,
United States Real Estate Corporation,
and
Cna Equities Group, Llc,
Rushmyfile,
Schwartz, Donald Esq,
United States Real Estate Corporation,
for (26) Unlimited Other Real Property
in the District Court of Santa Cruz County.
Preview
1 Donald Charles Schwartz, Esq. (SBN 122476)
2 Law Offices of Donald C. Schwartz
7960 Soquel Drive, No. 291
3 Aptos, CA 95003
4 831-331-9909; Facsimile 815-301-6556
Attorney for Cross-Defendant
5 Donald Charles Schwartz
(sued herein as Donald Schwartz)
6
7 SUPERIOR COURT OF CALIFORNIA
8 FOR THE COUNTY OF SANTA CRUZ
9 JASON NEEL, ) Case No. 22CV01758
10 )
Plaintiff, ) DECLARATION OF DONALD
11 ) CHARLES SCHWARTZ IN SUPPORT
12 vs. ) OF SPECIAL MOTION TO STRIKE -
) CCP §425.16)
13 SUPERIOR LOAN SERVICING; ASSET )
14
DEFAULT MANAGEMENT, INC.; )
UNITED STATES REAL ESTATE )
15 CORPORATION; CAN EQUITIES )
GROUP, LLC; AND RUSHMYFILE, )
16
BUSINESS ENTITY FORM UNKNOWN, ) Date: 4/22/24
17 and DOES 1-10, inclusive, ) Time: 8:30 am
) Dept.: 5 – Honorable Timothy Volkmann
18 Defendants. ) Trial Master Calendar: 8/1/24
19 UNITED STATES REAL ESTATE )
CORPORATION, )
20 )
21 Cross-Complainant, )
)
22 v. )
23 )
JASON NEEL; CNA EQUITY GROUP, INC.)
24 a professional corporation; a California )
25
Corporation; CODY MOLICA, and ROES 1- )
50, Inclusive, )
26 )
Cross-Defendants. )
27
____________________________________ )
28
1
1 RUSHMYFILE, INC., a California )
2 Corporation )
)
3 Cross-Complainant, )
4 )
v. )
5 )
CNA EQUITY GROUP, INC., a professional )
6
corporation; CODY MOLICA, an individual; )
7 DONALD SCHWARTZ, an individual; )
DEREK WHEAT AKA MIGUEL WHEAT )
8
AKA SAM WHEAT, an individual; and )
9 MOES 1-50, inclusive, )
)
10 Cross-Defendants. )
11 ___________________________________ )
12
I, Donald Charles Schwartz, declare as follows:
13
1. I am an attorney licensed to practice law in the State of California and was the attorney
14
of record for plaintiff Jason Neel in the herein civil action. The following facts are within my
15
personal knowledge and if called upon and sworn as a witness, I could and would testify
16
competently to them.
17
2. The factual allegations regarding the real property transactions which form the basis for
18
the assertions set forth in the cross-complaint by United State Real Estate Corporation
19
(“USREC”) include privileged communications with my client, Jason Neel.
20
3. I am not apprised that Mr. Neel has waived these confidences.
21
I declare under penalty of perjury under the laws of the State of California that the
22
foregoing is true and correct and that this declaration was executed on February 13, 2024 at
23
Aptos, California.
24
Date: February 13, 2024 /s/ Donald Charles Schwartz
25
__________________________
26 Donald Charles Schwartz
27
Attorney for Cross-Defendant
Donald Charles Schwartz
28
2
Document Filed Date
February 13, 2024
Case Filing Date
August 10, 2021
Category
(26) Unlimited Other Real Property
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