Party Statement: Fidelity National Title Insurance Company-V-Gonzalez, Et Al Print

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                                ELECTRONICALLY FILED
                                                                  SUPERIOR COURT OF CALIFORNIA
                                                                  COUNTY OF SAN BERNARDINO
                                                                  SAN BERNARDINO DISTRICT
     FIDELITY NATIONAL LAW GROUP
 1                                                                2/8/2024 10:02 PM
     MARY ANN ROUSSO (SBN 289426)
 2   601 So. Figueroa Street, Suite 4025                          By: Khiyara Frontela, DEPUTY
     Los Angeles, California 90017
 3   Telephone: 213-438-4416
     Facsimile: 213-438-4417
 4   Email: mary-ann.rousso@fnf.com
 5
 6                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
 7                    COUNTY OF SAN BERNARDINO, CENTRAL DISTRICT

 8                                                      )
     FIDELITY NATIONAL TITLE INSURANCE                      CASE NO.: CIV SB 2130313
 9   COMPANY, a Florida corporation,                    )
                                                        )   [Assigned to the Honorable Donald Alvarez,
10                   Plaintiff,                         )   Dept. S23-SVJC]
         v.                                             )
11                                                      )   DECLARATION OF MARY ANN
12   MARTIN GONZALEZ, aka MARTIN                        )   ROUSSO IN SUPPORT OF
     JESUS GONZALEZ, an individual; CESAR               )   PLAINTIFF'S OPPOSITION TO
13   MONTANO, aka CESAR MONTANO, JR.,                   )   GOLDEN RULE LENDING, LLC'S
     an individual; GOLDEN RULE LENDING,                )   MOTION TO QUASH SUBPOENA OF
14                                                      )   RECORDS TO WELLS FARGO BANK
     LLC, a California Limited Liability
15   Company; DOES 1 through 100, inclusive,            )
                                                        )   Date: February 22, 2024
16                   Defendants.                        )   Time: 8:30 a.m.
                                                        )   Dept.: S23-SBJC
17                                                      )
                                                        )
18
      __________                                        )
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21            I, MARY ANN ROUSSO, declare and say that:

22                  I am counsel for Plaintiff in this action. If called upon as a witness, I could and
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     would testify competently to the within matters which are of my own personal knowledge. I
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     make this declaration in support of Plaintiffs Opposition to Defendant Golden Rule Lending,
25
     LLC's Motion to Quash Subpoena of Records to Wells Fargo Bank scheduled for hearing at the
26
27   date, time and place referenced above.

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     DECLARATION OF MARY ANN ROUSSO IN SUPPORT OF PLAINTIFF'S OPPOSITION TO GOLDEN
     RULE LENDING, LLC'S MOTION TO QUASH SUBPOENA OF RECORDS TO WELLS FARGO BANK
,1           2. On or about December 22, 2023, I prepared and submitted a Notice of Related Case in

 2   this action, listing all the related cases related to this matter. A true and correct copy of said

 3   Notice of Related Case is attached hereto as Exhibit M-1 and incorporated herein by this
 4   reference.
 5
             3. On or about January 20, 2023, pursuant to discovery propounded upon Defendant,
 6
     Golden Rule Lending, LLC by Plaintiff consisting of ( 1) Request for Admissions; (2) Form
 7
 8   Interrogatories; (3) Special Interrogatories; and (4) Request for Production of Documents, I

 9   received the attached Responses from Defendant, Golden Rule Lending, LLC. (collectively
10   "Written Responses from GRL"). True and correct copies of said Written Responses from GRL
11
     are being lodged with the Court, marked as Exhibit M-2, to protect certain private information.
12
             4. On January 30, 2023, pursuant to discovery propounded upon Defendant Cesar
13
14   Montano, aka Cesar Montano, Jr. ("Montano") by Plaintiff consisting of (1) Request for

15   Admissions; (2) Form Interrogatories; (3) Special Interrogatories; and (4) Request for Production
16
     of Documents, I received the attached Responses from Defendant, Montano for each of the
17
     discovery requests. (collectively "Written Responses from Montano"). True and correct copies of
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     said Written Responses from Montano are being lodged with the Court, marked as Exhibit M-3, to
19

20   protect certain private information.

21           I declare under penalty of perjury under the laws of the State of California that the
22   foregoing is true and correct. Executed this 7th day of February, 2024 at Los Angeles, California.
23
24                                                   Respectfully submitted,

25                                                   FIDELITY NATIONAL LAW GROUP
26
                                                       ca        Rousso, Attorney for Plaintiff,
27                                                          ELITY NATIONAL TITLE INSURANCE CO.

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      DECLARATION OF MARY ANN ROUSSO IN SUPPORT OF PLAINTIFF'S OPPOSITION TO GOLDEN
      RULE LENDING, LLC'S MOTION TO QUASH SUBPOENA OF RECORDS TO WELLS FARGO BANK