On October 22, 2021 a
Party Statement
was filed
involving a dispute between
Fidelity National Title Insurance Company,
and
Does 1-100,
Golden Rule Lending, Llc,
Gonzales, Martin,
Gonzalez, Martin,
Montano, Cesar,
for Fraud Unlimited
in the District Court of San Bernardino County.
Preview
\a
FIDELITY NATIONAL LAW GROUP v-UVTQHSUHO
MARY ANN ROUSSO (SBN 289426)
601 So. Figueroa Street, Suite 4025
Los Angelcs, California 90017
Telephone: (213) 438-4416
Facsimile: (21 3) 438-4417 “-3i
Email: mm-ann.rowg@fnf.com 3XV
0L-
Attorneys for Plaintiff,
FIDELITY NATIONAL TITLE
\OOOQQLA#UJNH
INSURANCE COMPANY
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
FIDELITY NATIONAL TITLE INSURANCE Case No.: CIVSB2130313
I—U—l—I
N—o
COMPANY,
[Assigned to Hon. Donald Alvarez, Dept. 823]
Plaintifi',
13’; vs.
DECLARATION OF MARY ANN ROUSSO
‘14
MARTIN GONZALEZ, et aL, RE STATUS OF CASE
15
Defendants.
16 Date: August 29, 2023
Time: 9:00 a.m.
17 Dept: 823 — SBJC
18
19 I, Mary Ann Rousso, declare as follows:
20 l. I am an attorney, duly licensed to practice law in the State of California and am a
21
I
member of Fidelity National Law Group, attorneys ofrecord for Plaintifi, FIDELITY NATIONAL
22 TITLE INSURANCE COMPANY (“Plaintifi”) in the above captioned action. The following facts
23 personal knowledge and, if called as a witness, could and would testify
are of my own I
24 competently thereto. I submit this Declaration for the continued Trial Setting Conference on
25 August 29, 2023 in this action.
26 2. The Complaint in this action was filed against all defendants on October 22, 2021.
Ii
27 There are three (3) defendants in this action, to wit:
28 A. Martin Gonzalez aka Martin Jesus Gonzalez, an individual
(“GONZALEZ”).
PROOF OF SERVICE
V x.
GONZALEZ has been served by substitute service but has failed to file an Answer or other
responsive pleading to Plaintiff’s Complaint. I have had occasion to speak with Mr. Gonzalez
personally and notified him of Plaintifi‘s lawsuit served on him; however, when Mr. Gonzalez
realized what the nature of my call was, Mr. Gonzalez hung up the telephone and terminated the
oooqomkwto—
telephone conversation. GONZALEZ’s default was requested on May 25, 2023. Although the
Court has acknowledged receipt of Plaintiff’s request for the entry of default against defendant
GONZALEZ, the default has not been entered to date. Plaintiff is waiting to file its Application
for Default Judgment, pursuant to CA Civil Code § 579 (severed judgment) as soon as the default
of GONZALEZ is entered by the Court. A true and correct copy of the Request for Entry of
Default against GONZALEZ is attached hereto as Exhibit l.
B. Cesar Montano, aka Cesar Montano, Jr., an individual (“MONTANO”) was
also
served with Plaintiff‘s Summons and Complaint (and all related coun notices) on April 5, 2022.
MONTANO filed an Answer on May 28, 2022. The matter is currently in discovery.
C. Golden Rule Lending, LLC, a California Limited Liability Company
(“GOLDEN RULE”), was served with Plaintiff’s Summons and Complaint (and all related court
notices) on April 5, 2022. GOLDEN RULE filed an Answer on May 28, 2022. The matter is
NNNNNNNNNHu—n—nt—Iu—o—n—a—n—n.‘
currently in discovery.
I declare under penalty of perjury under the laws of the State of California that the
OOQO\U~#WN—O\O°°QO\MAWN—O
foregoing is true and correct.
Executed this 28‘“ day of August, 2023 at Los Angclcs, California.
Date: August 28, 2023 FIDELITY NATIONAL LAW GROUP
MARY ANN ROUSSO
Attorneys for Plaintiff, FIDELITY NATIONAL
TITLE INSURANCE COMPANY
PROOF 0F SERVICE
Document Filed Date
August 28, 2023
Case Filing Date
October 22, 2021
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\a FIDELITY NATIONAL LAW GROUP v-UVTQHSUHO MARY ANN ROUSSO (SBN 289426) 601 So. Figueroa Street, Suite 4025 Los Angelcs, California 90017 Telephone: (213) 438-4416 Facsimile: (21 3) 438-4417 “-3i Email: mm-ann.rowg@fnf.com 3XV 0L- Attorneys for Plaintiff, FIDELITY NATIONAL TITLE \OOOQQLA#UJNH INSURANCE COMPANY SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT FIDELITY NATIONAL TITLE INSURANCE Case No.: CIVSB2130313 I—U—l—I N—o COMPANY, [Assigned to Hon. Donald Alvarez, Dept. 823] Plaintifi', 13’; vs. DECLARATION OF MARY ANN ROUSSO ‘14 MARTIN GONZALEZ, et aL, RE STATUS OF CASE 15 Defendants. 16 Date: August 29, 2023 Time: 9:00 a.m. 17 Dept: 823 — SBJC 18 19 I, Mary Ann Rousso, declare as follows: 20 l. I am an attorney, duly licensed to practice law in the State of California and am a 21 I member of Fidelity National Law Group, attorneys ofrecord for Plaintifi, FIDELITY NATIONAL 22 TITLE INSURANCE COMPANY (“Plaintifi”) in the above captioned action. The following facts 23 personal knowledge and, if called as a witness, could and would testify are of my own I 24 competently thereto. I submit this Declaration for the continued Trial Setting Conference on 25 August 29, 2023 in this action. 26 2. The Complaint in this action was filed against all defendants on October 22, 2021. Ii 27 There are three (3) defendants in this action, to wit: 28 A. Martin Gonzalez aka Martin Jesus Gonzalez, an individual (“GONZALEZ”). PROOF OF SERVICE V x. GONZALEZ has been served by substitute service but has failed to file an Answer or other responsive pleading to Plaintiff’s Complaint. I have had occasion to speak with Mr. Gonzalez personally and notified him of Plaintifi‘s lawsuit served on him; however, when Mr. Gonzalez realized what the nature of my call was, Mr. Gonzalez hung up the telephone and terminated the oooqomkwto— telephone conversation. GONZALEZ’s default was requested on May 25, 2023. Although the Court has acknowledged receipt of Plaintiff’s request for the entry of default against defendant GONZALEZ, the default has not been entered to date. Plaintiff is waiting to file its Application for Default Judgment, pursuant to CA Civil Code § 579 (severed judgment) as soon as the default of GONZALEZ is entered by the Court. A true and correct copy of the Request for Entry of Default against GONZALEZ is attached hereto as Exhibit l. B. Cesar Montano, aka Cesar Montano, Jr., an individual (“MONTANO”) was also served with Plaintiff‘s Summons and Complaint (and all related coun notices) on April 5, 2022. MONTANO filed an Answer on May 28, 2022. The matter is currently in discovery. C. Golden Rule Lending, LLC, a California Limited Liability Company (“GOLDEN RULE”), was served with Plaintiff’s Summons and Complaint (and all related court notices) on April 5, 2022. GOLDEN RULE filed an Answer on May 28, 2022. The matter is NNNNNNNNNHu—n—nt—Iu—o—n—a—n—n.‘ currently in discovery. I declare under penalty of perjury under the laws of the State of California that the OOQO\U~#WN—O\O°°QO\MAWN—O foregoing is true and correct. Executed this 28‘“ day of August, 2023 at Los Angclcs, California. Date: August 28, 2023 FIDELITY NATIONAL LAW GROUP MARY ANN ROUSSO Attorneys for Plaintiff, FIDELITY NATIONAL TITLE INSURANCE COMPANY PROOF 0F SERVICE