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answer to ud -

answer to ud -

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Published by tmccand

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Published by: tmccand on Nov 01, 2009
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06/10/2013

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ANSWER TO COMPLAINT
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KATRINA GJURASHAJ
34202 PINEHURST DRIVE,
YUCAIPA, CA 92399
Phone (951) 801-9526

Defendant In Pro Se
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE,
Plaintiff,
Vs.

ROBERT GJOLAJ; MINERVA A.
TOLOMA; and DOES 1 through 6,
inclusive

Defendant.
Case No.: UDSS 802-816
ANSWER TO COMPLAINT FOR
UNLAWFUL DETAINER

Defendant KATRINA GJURASHAJ answering as one of the doe defendants
herein denies generally and specifically each of the allegations of the complaint on file
herein..

FIRST AFFIRMATIVE DEFENSE
Plaintiffs lack Standing as they were not the BENEFICIARY of the note and another
party has unlawfully foreclosed thereon and this matter is before this court as
Case Number CIVSS-805619; Judge ALVAREZ
SECOND AFFIRMATIVE DEFENSE
Deutsche Bank was not the beneficiary of this Note
the actual Beneficiary remained in hiding
during the entire foreclosure process.

ANSWER TO COMPLAINT
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And the wrong party has foreclosed.
Plaintiffs are not the right party to bring this foreclosure action.
\u201cAs they lack standing\u201d
THIRD AFFIRMATIVE DEFENSE
Plaintiffs can not establish that they are in the chain of title
FOURTH AFFIRMATIVE DEFENSE
Plaintiffs can not establish that
they paid consideration for this note and mortgage
FIFTH AFFIRMATIVE DEFENSE
Plaintiff\u2019s can not establish that they owned
this note and mortgage at the time of the default
SIXTH AFFIRMATIVE DEFENSE
The notices served on defendants were defective under California Law
SEVENTH AFFIRMATIVE DEFENSE
The real beneficiary is STILLcurrently unknown
EIGHTH AFFIRMATIVE DEFENSE
The Complaint, fails to state
a cause of action against these answering defendants.
NINTH AFFIRMATIVE DEFENSE
The Complaint is not properly verified
IT MUST BE VERIFIED BY A PARTY
TENTH AFFIRMATIVE DEFENSE
Plaintiff does not have effective title
as alleged in the Complaint, nor as required by law.
ELEVENTH AFFIRMATIVE DEFENSE
The Complaint was filed prematurely

ANSWER TO COMPLAINT
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TWELFTH AFFIRMATIVE DEFENSE
The complaint fails to state sufficient facts to warrant the FORECLOSURE of
defendants PROPERTY AND AN EVICTION THEREOF
THIRTEENTH AFFIRMATIVE DEFENSE
Plaintiff is barred by the doctrine of UNCLEAN HANDS.
FOURTEENTH AFFIRMATIVE DEFENSE

The EVICTION IS BEING conducted by a party who was not properly authorized
or appointed by the Beneficiary\u2019, AND WHO IS NOT THE BENEFICIARY

FIFTEENTH AFFIRMATIVE DEFENSE
Plaintiff does not have clean hands as Plaintiff has committed a FRAUD by double
securitizing Plaintiff\u2019s Note. And therefore IS not the proper party to participate in the
foreclosure OR THIS EVICTION.
SIXTEENTH AFFIRMATIVE DEFENSE
Defendants HAVE FILED a claim against Plaintiff for Fraud and will move this court to
consolidate both cases for trial.
SEVENTEENTH AFFIRMATIVE DEFENSE
Defendants attach hereto AND INCORPORATE AS PART OF THEIR AFFIRMATIVE
DEFENSES true and correct copies of Ohio Federal Court decisions where as here
DEUTSCHE BANK WAS FOUND TO BE THE WRONG PARTY AND THOSE
FORECLOSURES WERE DISMISSED.
EIGHTEENTH AFFIRMATIVE DEFENSE
Defendants attach hereto AND INCORPORATE AS PART OF THEIR AFFIRMATIVE
DEFENSES A true and correct copy of their first amended complaint against this
Plaintiff for among other claims FRAUD
WHEREFORE, Defendants, and each of them pray for judgment as follows:

A. That Plaintiff take nothing by way of the complaint; and
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