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BRYAN CAVE LL
THREE EMBARCADERO CENT
SAN FRANCISCO, CA 94111-4070
BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Three Embarcadero Center, 7th Floor
San Francisco, CA 94105-2994
Telephone: (415) 675-3400
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com
goli.mahdavi@bryancave.com
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
07/12/2017
Clerk of the Court
BY: MADONNA CARANTO.
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG,
Plaintiff,
Vv.
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Defendants.
SFOIDOCS\306706.1
Case No. CGC-15-546377
NOTICE OF ENTRY OF ORDER
June 16, 2015
August 21, 2017
Complaint Filed:
Trial Date:
NOTICE OF ENTRY OF ORDERBRYAN CAVE LLP,
THREE EMBARCADERO CENTER, 7" FLOOR
SAN FRANCISCO, CA 94111-4077;
TO PLAINTIFF AND THE CLERK OF THE COURT:
PLEASE TAKE NOTICE that on July 10, 2017, the Court in the above-captioned action
entered an Order to Show Cause re: Contempt and Sanctions. The Order is attached hereto as
Exhibit A and incorporated by this reference.
Dated: July 12, 2017 Respectfully submitted,
BRYAN CAVE LLP
Daniel Rockey
Goli Mahdavi
VW
By:
Goli) Mahdavi
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
SFOLDOCS1306706.1 1
NOTICE OF ENTRY OF ORDEREXHIBIT ABRYAN CAve LLP.
SAN FRANCISCO, CA 941
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BRYAN CAVE LLP
Daniel T. Rockey, California Bar No. 178604
Goli Mahdavi, California Bar No. 245705
Three Embarcadero Center, 7th Floor
San Francisco, CA 94111
Telephone: (415) 675-3400
Facsimile: (415) 675-3434
E-Mail: daniel.rockey@bryancave.com
goli.mahdavi@bryancave.com
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
FI
iL x D
Ounity of ant ranel eae
JUL 1 0 2017
CLERK < RE COURT
BY
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
MARTIN ENG,
Plaintiff,
v.
JPMORGAN CHASE BANK, N.A.;
QUALITY LOAN SERVICES; LENDER
PROCESSING SERVICES, INC., DOES 1-
1000 inclusive,
Case No. CGC-15-546377
a
[PROPOSED] ORDER TO SHOW CAUSE
RE: CONTEMPT AND SANCTIONS
10
Date: July N, 2017
Time: 9:80 a.m.
Dept.: 302 - DISCOVERY
Defendants.
Complaint Filed: June 16, 2015
Trial Date: August 21, 2017
SFOIDOCS\05061.1 /
a ORDERBRYAN Cave LLP
THREE EMBARCADERO CENTER, 7 FLOOR
SAN FRANCISCO, CA 94111-4070
WU RB Bw NM
Co ew NUN A
TO PLAINTIFF MARTIN ENG:
Defendant JPMorgan Chase Bank, N.A. (“Defendant”) has presented to this Court
sufficient grounds to initiate contempt proceedings; therefore, YOU ARE HEREBY ORDERED
to appear on August F 2017 at 130. a.m/pan-in Department 302 of the above entitled court,
located at 400 McAllister Street, San Francisco, California 94102, to show cause as to why you
should not be held in contempt of this Court’s Order dated February 3, 2017 (the “Order”),
ordering you to pay Defendant $2,150 in monetary sanctions.
In particular, you are ordered to show cause why:
1. Plaintiff should not be held in contempt for willfully failing to comply with the
Order, and that Plaintiff not be imprisoned up to five (5) days in jail and/or ordered to pay a fine in
the amount of $1,000;
2. Plaintiff should not pay to the Court a sum of at least $1,500, pursuant to Code of
Civil Procedure section 177.5 and California Rule of Court Rule 2.30; and
3. Plaintiff should not pay to Defendant its legal fees and costs incurred in this
contempt and sanctions proceeding, in the sum of at least $2,425.
IT IS FURTHER ORDERED THAT any opposition papers to the Order to Show Cause
shall be filed and served on Defendant by e-mail and overnight delivery to Defendant’s counsel no
later than July 25, 40(T any reply papers to the opposition shall be filed and served on counsel
for Plaintiff by e-mail and overnight delivery no later than Agust j 26 t
IT IS SO ORDERED
Dated: 0/12 . F hukd BIIY.
Judge of the Superior Court of San Francisco County
L4pr/, PRICHARD ULMER
‘SFO1DOCS\305061.1
fi
“en ORDER8
8
BRYAN CAVE LL
THREE EMBARCADERO CENT
SAN FRANCISCO, CA 94111-4070
PROOF OF SERVICE
I am employed by Bryan Cave LLP, with an office located in the County of San
Francisco, State of California. I am over the age of 18 and not a party to the within action.
My business address is Three Embarcadero Center 7 Floor, San Francisco, California
94111.
On July 12, 2017, I caused to be served on the interested parties on said action the
within:
NOTICE OF ENTRY OF ORDER
by placing a true copy thereof in a sealed envelope(s) addressed to each as follows:
Michael J. McLaughlin Attorney for Plaintiff
McLaughlin Yeh LLP
351 California Street, Suite 325
San Francisco, CA 94104
Phone: (415) 655-9753
Fax: (415) 680-1701
Attorney for Plaintiff
Email: mmclaughlin@mclaughlinyeh.com
Leticia Butler, Esq. Attorneys for Quality Loan Service Corp.
McCarthy & Holthus, LLP
1770 4" Avenue
San Diego, CA 92101
Tel: (619) 685-4800
Fax: (619) 685-4811
Email: Ibutler@meccarthyholtus.com
BY U.S. MAIL: I am “readily familiar” with the firm’s practice of
collection and processing correspondence for mailing. Under that practice it would be
deposited with U.S. postal service on that same day with postage thereon fully prepaid at
San Francisco, California, in the ordinary course of business. | am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter
date is more than one day after date of deposit for mailing in affidavit.
&] (STATE) I declare under penalty of perjury the laws of the State of
California that the above is true and correct.
< “cen 7 ol 42 ip
/ Janette Palagarids
fo
SFO] DOCS\306706.1
PROOF OF SERVICE
Preview
8 8 BRYAN CAVE LL THREE EMBARCADERO CENT SAN FRANCISCO, CA 94111-4070 BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Three Embarcadero Center, 7th Floor San Francisco, CA 94105-2994 Telephone: (415) 675-3400 Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com goli.mahdavi@bryancave.com Attorneys for Defendant JPMORGAN CHASE BANK, N.A. ELECTRONICALLY FILED Superior Court of California, County of San Francisco 07/12/2017 Clerk of the Court BY: MADONNA CARANTO. Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Plaintiff, Vv. JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Defendants. SFOIDOCS\306706.1 Case No. CGC-15-546377 NOTICE OF ENTRY OF ORDER June 16, 2015 August 21, 2017 Complaint Filed: Trial Date: NOTICE OF ENTRY OF ORDERBRYAN CAVE LLP, THREE EMBARCADERO CENTER, 7" FLOOR SAN FRANCISCO, CA 94111-4077; TO PLAINTIFF AND THE CLERK OF THE COURT: PLEASE TAKE NOTICE that on July 10, 2017, the Court in the above-captioned action entered an Order to Show Cause re: Contempt and Sanctions. The Order is attached hereto as Exhibit A and incorporated by this reference. Dated: July 12, 2017 Respectfully submitted, BRYAN CAVE LLP Daniel Rockey Goli Mahdavi VW By: Goli) Mahdavi Attorneys for Defendant JPMORGAN CHASE BANK, N.A. SFOLDOCS1306706.1 1 NOTICE OF ENTRY OF ORDEREXHIBIT ABRYAN CAve LLP. SAN FRANCISCO, CA 941 « 8 S a 6 2 = a - ya aA We wWwN BRYAN CAVE LLP Daniel T. Rockey, California Bar No. 178604 Goli Mahdavi, California Bar No. 245705 Three Embarcadero Center, 7th Floor San Francisco, CA 94111 Telephone: (415) 675-3400 Facsimile: (415) 675-3434 E-Mail: daniel.rockey@bryancave.com goli.mahdavi@bryancave.com Attorneys for Defendant JPMORGAN CHASE BANK, N.A. FI iL x D Ounity of ant ranel eae JUL 1 0 2017 CLERK < RE COURT BY Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO MARTIN ENG, Plaintiff, v. JPMORGAN CHASE BANK, N.A.; QUALITY LOAN SERVICES; LENDER PROCESSING SERVICES, INC., DOES 1- 1000 inclusive, Case No. CGC-15-546377 a [PROPOSED] ORDER TO SHOW CAUSE RE: CONTEMPT AND SANCTIONS 10 Date: July N, 2017 Time: 9:80 a.m. Dept.: 302 - DISCOVERY Defendants. Complaint Filed: June 16, 2015 Trial Date: August 21, 2017 SFOIDOCS\05061.1 / a ORDERBRYAN Cave LLP THREE EMBARCADERO CENTER, 7 FLOOR SAN FRANCISCO, CA 94111-4070 WU RB Bw NM Co ew NUN A TO PLAINTIFF MARTIN ENG: Defendant JPMorgan Chase Bank, N.A. (“Defendant”) has presented to this Court sufficient grounds to initiate contempt proceedings; therefore, YOU ARE HEREBY ORDERED to appear on August F 2017 at 130. a.m/pan-in Department 302 of the above entitled court, located at 400 McAllister Street, San Francisco, California 94102, to show cause as to why you should not be held in contempt of this Court’s Order dated February 3, 2017 (the “Order”), ordering you to pay Defendant $2,150 in monetary sanctions. In particular, you are ordered to show cause why: 1. Plaintiff should not be held in contempt for willfully failing to comply with the Order, and that Plaintiff not be imprisoned up to five (5) days in jail and/or ordered to pay a fine in the amount of $1,000; 2. Plaintiff should not pay to the Court a sum of at least $1,500, pursuant to Code of Civil Procedure section 177.5 and California Rule of Court Rule 2.30; and 3. Plaintiff should not pay to Defendant its legal fees and costs incurred in this contempt and sanctions proceeding, in the sum of at least $2,425. IT IS FURTHER ORDERED THAT any opposition papers to the Order to Show Cause shall be filed and served on Defendant by e-mail and overnight delivery to Defendant’s counsel no later than July 25, 40(T any reply papers to the opposition shall be filed and served on counsel for Plaintiff by e-mail and overnight delivery no later than Agust j 26 t IT IS SO ORDERED Dated: 0/12 . F hukd BIIY. Judge of the Superior Court of San Francisco County L4pr/, PRICHARD ULMER ‘SFO1DOCS\305061.1 fi “en ORDER8 8 BRYAN CAVE LL THREE EMBARCADERO CENT SAN FRANCISCO, CA 94111-4070 PROOF OF SERVICE I am employed by Bryan Cave LLP, with an office located in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action. My business address is Three Embarcadero Center 7 Floor, San Francisco, California 94111. On July 12, 2017, I caused to be served on the interested parties on said action the within: NOTICE OF ENTRY OF ORDER by placing a true copy thereof in a sealed envelope(s) addressed to each as follows: Michael J. McLaughlin Attorney for Plaintiff McLaughlin Yeh LLP 351 California Street, Suite 325 San Francisco, CA 94104 Phone: (415) 655-9753 Fax: (415) 680-1701 Attorney for Plaintiff Email: mmclaughlin@mclaughlinyeh.com Leticia Butler, Esq. Attorneys for Quality Loan Service Corp. McCarthy & Holthus, LLP 1770 4" Avenue San Diego, CA 92101 Tel: (619) 685-4800 Fax: (619) 685-4811 Email: Ibutler@meccarthyholtus.com BY U.S. MAIL: I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business. | am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. &] (STATE) I declare under penalty of perjury the laws of the State of California that the above is true and correct. < “cen 7 ol 42 ip / Janette Palagarids fo SFO] DOCS\306706.1 PROOF OF SERVICE