Verified Complaint / Rousseau v. Wells Fargo, Et Al. Page -2-
Plaintiffs are informed and believe, and thereon allege that Defendant WELLS FARGOBANK, N.A. (Hereinafter “WFB”), a national bank association with a principle place of businessin Sioux Falls, South Dakota, is the successor in interest to Wachovia Mortgage, FSB, who inturn was the successor in interest to the originator of the Subject Loan, World Savings Bank,FSB. WF purportedly acquired title to the Subject Property at a foreclosure sale on November 22, 2010.3.
Plaintiffs are informed and believe, and thereon allege that Defendant WACHOVIAMORTGAGE, form unknown, is now a division of WELLS FARGO BANK. WACHOVIA wasthe originator of the Subject Loan (using the WORLD SAVINGS BANK tradename); after itacquisition/merger with WFB, WACHOVIA purportedly serviced the loan on behalf of WFB.4.
Plaintiffs are informed and believe, and thereon allege that Defendant REGIONALSERVICE CORPORATION, (Hereafter “RSC”), organized under the state of California, with its principle place of business in Seattle, Washington, is a licensed California Corporation in the business of acting as a non-judicial foreclosure trustee. RSC purportedly acted as a dulysubstituted trustee in conducting the foreclosure sale of the Subject Property.5.
Defendant DOES 1 - 20 are sued by their fictitious names pursuant to C.C.P. §494. Their true names and capacities are unknown to Plaintiff. Plaintiff will amend this complaint to allegetheir true names and capacities when ascertained.6.
Plaintiff believes that each fictitiously named Defendant DOE 1-10 is a person or entitywho participated in, assisted, advised, was retained by, or counseled by one of the other Defendants herein in connection with the acts alleged herein of which Plaintiff complains. Saidfictitiously named Defendants were agents, servants, employees, alter egos, superiors, successorsin interest, joint venturers and/ or co-conspirators of each of their co-defendants and in doing thethings herein after mentioned, or acting within the course and scope of their authority of suchagents, servants, employees, alter egos, superiors, successors in interest, joint venturers and/ or co-conspirators with the permission and consent of their co-defendants and, consequently, eachDefendant named herein, and those Defendants named herein as DOES 1 through 10, inclusive,are jointly and severally liable to Plaintiff for the damages and harm sustained as a result of their