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New Complaint With Instructions Pre-Foreclosure

New Complaint With Instructions Pre-Foreclosure

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Published by tmccand

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Published by: tmccand on Nov 22, 2009
Copyright:Attribution Non-commercial

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01/09/2015

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TIMOTHY L. MCCANDLESS, ESQ. SBN 147715LAW OFFICES OF TIMOTHY L. MCCANDLESS13240 Amargosa RoadVictorville, California 92392(760) 951-3663 Telephone(909) 382-9956 FacsimileAttorney for 
 Plaintiff,
Claudia M. Cardoza
SUPERIOR COURT FOR THE STATE OF CALIFORNIAIN AND FOR COUNTY OF LOS ANGELES
EDWIN LAUS,Plaintiff,V.AMERICAN BROKERS CONDUIT;DEFAULT RESOLUTION NETWORK;FIDELITY NATIONAL TITLE COMPANY,and DOES 1 through 50 inclusiveDefendants.CASE NO:
COMPLAINT FOR:MONETARY DAMAGESSTATUTORY DAMAGES, PUNITIVEDAMAGES, INJUNCTIVE RELIEF ANDDECLARATORY RELIEF
1. VIOLATION OF
CALIFORNIA CIVILCODE 
§2923.5;2. FRAUD;3.INTENTIONALMISREPRESENTATION;
4.
VIOLATION OF
CALIFORNIA CIVILCODE 
§2923.6;5. VIOLATION OF
CALIFORNIA CIVILCODE 
§1572;6. VIOLATION OF
 BUSINESS ANDPROFESSIONS CODE 
§17200.
Plaintiff,
 
CLAUDIA M. CARDOZA, (Hereinafter referred as “Plaintiff”) alleges herein asfollows:
1COMPLAINT
 
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GENERAL ALLEGATIONS
1.
Plaintiff CLAUDIA M. CARDOZA at all times relevant has been a resident of theCounty of Los Angeles, State of California and the owner of Real Property, including but not limited to the property at issue herein, 6101 Simpson Avenue, NorthHollywood, California 91606. The Legal descriptions are as follows:APN: 2334-013-845LOT 58 OF TRACT NO. 11466, IN THE CITY OF LOS ANGELES, COUNTYOF LOS ANGELES, STATE OF CALIFORNIA, AS PER MAP RECORDED INBOOK 205, PAGE 49 OF MAPS, IN THE OFFICE OF THE COUNTYRECORDER OF SAID COUNTY.
2.
DefendantTHE FIRST DEFENDANT IS ON THE DEED OF TRUST
AMERICANBROKERS CONDUIT, (hereinafter MAKE SURE TO APPREVIATE THEDEFENDANT
 “AMERICAN BROKERS”) at all times herein mentioned wasdoing business in the County of Los Angeles, State of California and was the originalLender for Plaintiff’s Deed of Trust Deed and Note.
3.
DefendantTHE SECOND DEFENDANT IS ON THE “NOTICE OF DEFAULT”
 DEFAULT RESOLUTION NETWORK, (hereinafter MAKE SURE TOAPPREVIATE THE DEFENDANT
“DEFAULT RESOLUTION”) at all timesherein mentioned is doing business in the County of Los Angeles, State of Californiaand was listed on the Notice of Default for the above named Real Property.
4.
DefendantTHE THIRD DEFENDANT IS ON THE “NOTICE OF TRUSTEE SALE”SOMETIMES IT IS THE SAME DEFENDANT AS THE NOTICE OF DEFAULT, IF
2COMPLAINT
 
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THAT IS THE CASE THE COPY AND PASTE “THE NOTICE OF TRUSTEESALE” AFTER THE WORDS NOTICE OF DEFAULT ABOVE AND DELETE NUMBER FOUR COMPLETELY
FIDELITY NATIONAL TITLE COMPANY,(hereinafter IF THE DEFENDANT ON THE “NOTICE OF TRUSTEE SALE”DIFFERS FROM THE DEFENDANT ON THE “NOTICE OF DEFAULT, MAKESURE TO APPREVIATE THE DEFENDANT
“FIDELITY”) at all times hereinmentioned is doing business in the County of Los Angeles, State of California and waslisted on the Notice of Trustee’s Sale for the above named Real Property.5.Plaintiff is ignorant of the true names and capacities of defendants sued herein asDOES 1 through 50, inclusive, and therefore sues these defendants by such fictitiousnames and all persons unknown claiming any legal or equitable right, title, estate, lien,or interest in the property described in the complaint adverse to plaintiff’s title, or anycloud on Plaintiff’s title thereto. Plaintiff will amend this complaint to allege their truenames and capacities when ascertained.6.Plaintiff is informed and believes and thereon alleges that, at all times hereinmentioned each of the defendants sued herein was the agent and employee of each of the remaining defendants. Plaintiff alleges that each and every defendant alleged hereinratified the conduct of each and every other defendant. Plaintiff further alleges that atall times said defendants were was acting within the purpose and scope of such agencyand employment.
7.
Plaintiff purchased the foregoing Real Property and on or aboutTHIS DATE CANEBE FOUND ON THE “DEED OF TRUST”
April 18, 2006 and financed his purchase throughDEFANDANT ON THE “DEED OF TRUST”
AMERICAN
3COMPLAINT

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