Re: John Rosenfeld v. Richard John Hernandez, etc., et al. (KC069410)

DEMURRER TO COMPLAINT; MOTION TO STRIKE PORTIONS OF COMPLAINT

Moving Parties: Defendants Andrew Quezada (erroneously sued as Andrew Ernie Quezada and also erroneously sued as Prime Equity Mortgage) and George Arias (erroneously sued as Joaquin George Arias and also erroneously sued as JNJ Properties, Inc. and also erroneously sued as Spectra Home Loans, Inc.)

Respondent: Plaintiff John Rosenfeld

POS: Moving OK; Opposing serve by regular mail contrary to CCP § 1005(c); Replies OK

Plaintiff alleges that, during the period from 8/15-12/16, he made loans to Richard John Hernandez aka Richard Hernandez aka Ricky Hernandez (“Hernandez”) and Andrew Ernie Quezada aka Andrew Quezada (“Quezada”) which they would lend out to third parties as part of their business making and arranging loans for third party borrowers. Plaintiff alleges that Hernandez has defaulted on promissory notes. Plaintiff alleges that defendants faile