Preview
Locke Lord LLP
101 Montgomery Street, Suite 1950
San Francisco, CA 94104
SUPERIOR FILED
c c -
LOCKE LORD LLP R COURT-STOCK Th
Regina J. McClendon (SBN 184669) 220 SEP-9 PH usad
rmcclendon@lockelord.com
Kinga L. Wright (SBN 313827)
kinga.wright@lockelord.com
101 Montgomery Street, Suite 1950
San Francisco, CA 94104
Telephone: (415) 318-8810
Fax: (415) 676-5816
Attorneys for Defendants
U.S. Bank National Association (sued herein as U.S. BANK N.A. and U.S. BANK NATIONAL
ASSOCIATION) and Mortgage Electronic Registration Systems, Inc. (sued as MORTGAGE
ELECTRONIC REGISTRATION SYSTEM AKA “MERS”)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN JOAQUIN
FELICIA JACINTA ANARO, an individual, CASE NO.: STK-CV-URP-2018-13317
Plaintiff, Assigned for all purposes to:
Hon. George J. Abdallah, Dept. 10A
vs.
)
)
)
)
U.S. BANK N.A.; U.S. BANK NATIONAL ) DECLARATION OF KINGA L. WRIGHT
ASSOCIATION; MORTGAGE ELECTRONIC ) IN SUPPORT OF DEMURRER AND
REGISTRATION SYSTEM, AKA “MERS”; ) MOTION TO STRIKE PLAINTIFF'S
GOVERNMENT NATIONAL MORTGAGE ) SECOND AMENDED COMPLAINT
ASSOCIATION AS TRUSTEE FOR )
SECURITIZED TRUST GINNIE MAE REMIC )
TRUST 2008-088; GINNIE MAE; AND DOES )
1 THROUGH 100, INCLUSIVE, )
)
)
Date: +04-4/2020,10/152020, or 10/16/2020
Time: 9:00 a.m.
Dept.: 10A
Defendants. Complaint Filed: October 23, 2018
I, Kinga L. Wright, declare:
1. I am an attorney licensed to practice in the State of California and employed as an
attorney by Locke Lord LLP, counsel for Defendants U.S. Bank National Association (sued herein
as U.S. BANK N.A. and U.S. BANK NATIONAL ASSOCIATION) and Mortgage Electronic
1
DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF DEMURRER AND MOTION TO STRIKE
Anaro v. Mason-McDuffie Mortgage Corporation and U.S. Bank, N.A.. et al.. Case No. STK-CV-URP-2018-13317
SRANDGN E. RILEY, CLERK
rt
BY FAXLocke Lord LLP
101 Montgomery Street, Suite 1950
San Francisco, CA 94104
oD Om Yt DH BF WY
Se oe ee ee ee eK
oe YN A A RF BW NH
21
Registration Systems, Inc. (sued as MORTGAGE ELECTRONIC REGISTRATION SYSTEM
AKA “MERS”) (together, “Defendants”) in the instant matter.
2. Plaintiff Felicia Jacinta Anaro is self-represented. Her phone number is (209) 923-
5029.
3. On September 2, 2020, at 4:13 p.m., I spoke with Ms. Anaro by telephone regarding
the grounds for Defendants’ anticipated demurrer to Plaintiff's Second Amended Complaint
(“SAC”) and motion to strike certain causes of action pled in the SAC. The parties discussed the
matter in earnest for 41 minutes, but did not reach an agreement resolving the objections raised in
the demurrer and motion to strike.
4, The patties continued to confer on September 3, 2020, at 1:31 p.m., for 34 minutes.
The parties again did not reach an agreement resolving the objections raised in the demurrer and
motion to strike.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct and that this declaration was executed on September 9, 2020, in San Francisco,
California.
Kinga.) Wright o
2
DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF DEMURRER AND MOTION TO STRIKE
Anaro v. Mason-McDuffie Mortgage Cornoration and U.S. Bank, N.A., et al. Case No. STK-CV-URP-2018-13317me
Locke Lord LLP
101 Montgomery Street, Suite 1950
San Francisen. CA 94104
STATE OF CALIFORNIA ) PROOF OF SERVICE
COUNTY OF SAN FRANCISCO ) ss.
Felicia Jacinta Anaro v. Mason-McDuffie Mortgage Corporation and U.S. Bank N.A., et al.
San Joaquin County Superior Court, Case No. STK-CV-URP-2018-13317
I am employed in the County of San Francisco, State of California. 1 am over the age of 18
and not a party to the within action. My business address is: 101 Montgomery Street, Suite 1950,
San Francisco, CA 94104. On September 9, 2020, I served the foregoing document described as:
DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF
DEMURRER AND MOTION TO STRIKE PLAINTIFF’S SECOND
AMENDED COMPLAINT
on the parties or attorneys for parties in this action who are identified below, using the following
means of service. (If more than one means of service is checked, the means of service used for each
party is indicated below).
Felicia Jacinta Anaro Plaintiff Pro Per
2432 Donatello Street
Manteca, CA 95337
Tel: (209) 302-2262
Email: anaro-felicia@comcast.net
James W. Brody, Esq.
Ryan F. Thomas, Esq. Attorneys for Defendant Mason-McDuffie
JOHNSTON THOMAS, Attorneys at Law, Mortgage Corporation
PC.
1400 N. Dutton Avenue, Suite 21
Santa Rosa, CA 95401
Tel: (707) 545-6542
Fax: (707) 545-1522
M BY MAIL. I placed the original or_v__a true copy of the foregoing document in a
sealed enveloped individually addressed to each of the parties listed above, and caused each
such envelope to be deposited in the mail at San Francisco, CA. Each envelope was mailed
with postage thereon fully prepaid. I am readily familiar with this firm’s practice of
collection and processing of correspondence for mailing. Under that practice, mail is
deposited with the United States Postal Service the same day that it is collected in the
ordinary course of business.
@ (State) I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed on September 9, 2020, at San Francisco, California.
ye Holmes
1
PROOF OF SERVICE
Anaro v. Mason-MeDuffie Mortgage Corporation and U.S. Bank N.A., et al, Case No. STK-CV-URP-2018-13317
Preview
Locke Lord LLP 101 Montgomery Street, Suite 1950 San Francisco, CA 94104 SUPERIOR FILED c c - LOCKE LORD LLP R COURT-STOCK Th Regina J. McClendon (SBN 184669) 220 SEP-9 PH usad rmcclendon@lockelord.com Kinga L. Wright (SBN 313827) kinga.wright@lockelord.com 101 Montgomery Street, Suite 1950 San Francisco, CA 94104 Telephone: (415) 318-8810 Fax: (415) 676-5816 Attorneys for Defendants U.S. Bank National Association (sued herein as U.S. BANK N.A. and U.S. BANK NATIONAL ASSOCIATION) and Mortgage Electronic Registration Systems, Inc. (sued as MORTGAGE ELECTRONIC REGISTRATION SYSTEM AKA “MERS”) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN JOAQUIN FELICIA JACINTA ANARO, an individual, CASE NO.: STK-CV-URP-2018-13317 Plaintiff, Assigned for all purposes to: Hon. George J. Abdallah, Dept. 10A vs. ) ) ) ) U.S. BANK N.A.; U.S. BANK NATIONAL ) DECLARATION OF KINGA L. WRIGHT ASSOCIATION; MORTGAGE ELECTRONIC ) IN SUPPORT OF DEMURRER AND REGISTRATION SYSTEM, AKA “MERS”; ) MOTION TO STRIKE PLAINTIFF'S GOVERNMENT NATIONAL MORTGAGE ) SECOND AMENDED COMPLAINT ASSOCIATION AS TRUSTEE FOR ) SECURITIZED TRUST GINNIE MAE REMIC ) TRUST 2008-088; GINNIE MAE; AND DOES ) 1 THROUGH 100, INCLUSIVE, ) ) ) Date: +04-4/2020,10/152020, or 10/16/2020 Time: 9:00 a.m. Dept.: 10A Defendants. Complaint Filed: October 23, 2018 I, Kinga L. Wright, declare: 1. I am an attorney licensed to practice in the State of California and employed as an attorney by Locke Lord LLP, counsel for Defendants U.S. Bank National Association (sued herein as U.S. BANK N.A. and U.S. BANK NATIONAL ASSOCIATION) and Mortgage Electronic 1 DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF DEMURRER AND MOTION TO STRIKE Anaro v. Mason-McDuffie Mortgage Corporation and U.S. Bank, N.A.. et al.. Case No. STK-CV-URP-2018-13317 SRANDGN E. RILEY, CLERK rt BY FAXLocke Lord LLP 101 Montgomery Street, Suite 1950 San Francisco, CA 94104 oD Om Yt DH BF WY Se oe ee ee ee eK oe YN A A RF BW NH 21 Registration Systems, Inc. (sued as MORTGAGE ELECTRONIC REGISTRATION SYSTEM AKA “MERS”) (together, “Defendants”) in the instant matter. 2. Plaintiff Felicia Jacinta Anaro is self-represented. Her phone number is (209) 923- 5029. 3. On September 2, 2020, at 4:13 p.m., I spoke with Ms. Anaro by telephone regarding the grounds for Defendants’ anticipated demurrer to Plaintiff's Second Amended Complaint (“SAC”) and motion to strike certain causes of action pled in the SAC. The parties discussed the matter in earnest for 41 minutes, but did not reach an agreement resolving the objections raised in the demurrer and motion to strike. 4, The patties continued to confer on September 3, 2020, at 1:31 p.m., for 34 minutes. The parties again did not reach an agreement resolving the objections raised in the demurrer and motion to strike. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on September 9, 2020, in San Francisco, California. Kinga.) Wright o 2 DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF DEMURRER AND MOTION TO STRIKE Anaro v. Mason-McDuffie Mortgage Cornoration and U.S. Bank, N.A., et al. Case No. STK-CV-URP-2018-13317me Locke Lord LLP 101 Montgomery Street, Suite 1950 San Francisen. CA 94104 STATE OF CALIFORNIA ) PROOF OF SERVICE COUNTY OF SAN FRANCISCO ) ss. Felicia Jacinta Anaro v. Mason-McDuffie Mortgage Corporation and U.S. Bank N.A., et al. San Joaquin County Superior Court, Case No. STK-CV-URP-2018-13317 I am employed in the County of San Francisco, State of California. 1 am over the age of 18 and not a party to the within action. My business address is: 101 Montgomery Street, Suite 1950, San Francisco, CA 94104. On September 9, 2020, I served the foregoing document described as: DECLARATION OF KINGA L. WRIGHT IN SUPPORT OF DEMURRER AND MOTION TO STRIKE PLAINTIFF’S SECOND AMENDED COMPLAINT on the parties or attorneys for parties in this action who are identified below, using the following means of service. (If more than one means of service is checked, the means of service used for each party is indicated below). Felicia Jacinta Anaro Plaintiff Pro Per 2432 Donatello Street Manteca, CA 95337 Tel: (209) 302-2262 Email: anaro-felicia@comcast.net James W. Brody, Esq. Ryan F. Thomas, Esq. Attorneys for Defendant Mason-McDuffie JOHNSTON THOMAS, Attorneys at Law, Mortgage Corporation PC. 1400 N. Dutton Avenue, Suite 21 Santa Rosa, CA 95401 Tel: (707) 545-6542 Fax: (707) 545-1522 M BY MAIL. I placed the original or_v__a true copy of the foregoing document in a sealed enveloped individually addressed to each of the parties listed above, and caused each such envelope to be deposited in the mail at San Francisco, CA. Each envelope was mailed with postage thereon fully prepaid. I am readily familiar with this firm’s practice of collection and processing of correspondence for mailing. Under that practice, mail is deposited with the United States Postal Service the same day that it is collected in the ordinary course of business. @ (State) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on September 9, 2020, at San Francisco, California. ye Holmes 1 PROOF OF SERVICE Anaro v. Mason-MeDuffie Mortgage Corporation and U.S. Bank N.A., et al, Case No. STK-CV-URP-2018-13317