12345678910111213141516171819202122232425262728upon information and belief, Home Mortgage was formerly a separate corporate entity known asWells Fargo Home Mortgage, Inc., but in or around May 2004, it merged with Wells Fargo andbecame a division of Wells Fargo. Thus, Wells Fargo and Home Mortgage are one and the sameand Wells Fargo is liable for any and all of Home Mortgage’s conduct alleged herein. Plaintiff hereinafter differentiates the two as Wells Fargo deceptively differentiated between the twoentities when dealing with Plaintiff.7. Plaintiff is informed and believes and based thereon alleges that First AmericanLoanstar Trustee Services LLC (“First American Loanstar”) is a Texas limited liability companyin the business of conducting non-judicial foreclosures in California.8. Plaintiff is informed and believes and based thereon alleges that First AmericanTitle Insurance Company (“First American Title”) is a California corporation with its principalplace of business in California. First American Title is in the business of conducting non-judicial foreclosures in California and/or assisting foreclosure trustees (hereinafter, “FirstAmerican Loanstar” and “First American Title” shall be collectively referred to as “FirstAmerican.”9. The defendants herein named as “all persons unknown, claiming any legal or equitable right, title, estate, lien, or interest in the property described in the complaint adverse toplaintiff’s title or any cloud on plaintiff’s title thereto” are hereinafter sometimes referred to asthe “unknown defendants” and are unknown to Plaintiff. These unknown defendants and eachof them claim or appear to claim some right, title, estate, lien, or interest in the propertydescribed in Paragraph 18 herein, adverse to Plaintiff’s title. Their claims, and each of them,constitute a cloud on Plaintiff’s title to the property.10. Plaintiff is ignorant of the true names and capacities of defendants sued herein asDOES 1 through 10, inclusive, and therefore sues these defendants by such fictitious names andall persons unknown claiming any legal or equitable right, title, estate, lien, or interest in theproperty described in this complaint adverse to Plaintiff’s title, or any cloud on Plaintiff’s titlethereto. Plaintiff will amend this complaint to allege their true names and capacities whenascertained.11. Defendants sued herein as DOES 1 through 10 are contractually, strictly,negligently, intentionally, vicariously liable and or otherwise legally responsible in some manner for each and every act, omission, obligation, event or happening set forth in this Complaint, andthat each of said fictitiously named Defendants is indebted to Plaintiff as hereinafter alleged.