Case 2:09-cv-04589-AHM-AJW Document 123 Filed 09/13/10 Page 1 of 4 Page ID #:1134

1 PAUL NGUYEN
LAURA NGUYEN
2 16141 Quartz Street
Westminster, CA 92683
3 Teler.hone: (714) 360-7602
EmaIl: mnapaulf@gmail.com
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Plaintiffs in Pro Persona
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
~ - ­

Pl
o
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PAUL NGUYEN, an individual; and
Case No. CV09-4589 ~ (AJWx)
13 LAURA NGUYEN, an individual,
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Plaintiffs,
v.
18 Chase Bank USA, N.A.; Chase Home
Finance, LLC; First American Loanstar
19 Trustee Services.
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Defendants.
NOTICE OF PLAINTIFFS' MOTION
AND MOTION FOR ENTRY OF
DEFAULT JUDGMENT.
DATE:
TIME:
ROOM:
OCT. 4, 2010
10:00 AM
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HON. A. HOWARD MATZ
TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that on October 4,2010, at 10:00 AM or as soon
24 thereafter as the matter may be heard, Plaintiff Paul Nguyen and Laura Nguyen will
25 move the above entitled Court for entry of Judgment by Default against defendants
Chase Bank USA, N.A., Chase Home Finance, LLC and First American Loanstar
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Trustee Services, for rescission and damages 15 U.S.C. § 1635, 12 C.F.R. § 226, 12
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U.S.C. § 2601 et.seq., quiet title, and State unfair business practice, for punitive
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NOTICE OF PLAINTIFFS' MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT.
Case 2:09-cv-04589-AHM-AJW Document 123 Filed 09/13/10 Page 2 of 4 Page ID #:1135
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damages under State law, for Judgment compelling Defendant to reconvey deed of
trust, and for plaintiffs' costs.
This Motion is made upon the following ground, as set forth more fully in the
supporting papers filed and served with this Notice of Motion and Motion:
l. Pursuant to the Court's August 23,2010 Minute Order, the Court enter
default judgment against defendants Chase Bank USA, N.A. and Chase Home
Finance, LLC on Plaintiffs' Second Amended Complaint.
2. Court held in abeyance all claims against defendant First American
Loanstar because Plaintiffs were unsure as to what claims are against this Defendant.
Plaintiffs are now requesting the Court to enter judgment against Defendant First
American Loanstar Trustee Services as non-monetary status with regard to the Deed
of Trust. [Docket # 85].
3. Defendant Chase Bank USA, NA intentionally forged the signature of
Plaintiff Laura Nguyen onto the Deed of Trust, Notice of Right to Cancel and other
documents related to the mortgage loan (1 st Claim for Relief).
4. Plaintiffs exercised their rights to rescind the mortgage loan and made
offer to tender. Defendant Chase Bank USA, NA refused to rescind Plaintiffs' loan
in their willful violations of law (2
nd
Claim for Relief).
5.
Defendant Chase Home Finance, LLC failed to response to Plaintiff
Paul Nguyen Qualified Written Request sent on April 8, 2009 as required by laws
(3
rd
Claim for Relief).
6. The conducts of Defendant Chase Bank USA, NA and Chase Home
Finance, LLC constitute unfair business practice pursuant to California Business and
Professions § 17200 et.seq. (4
th
Claim for relief).
7.
Defendants Chase Bank USA, NA and First American Loanstar Trustee
Services wrongfully claims interest in Plaintiffs' property and such claims are quiet
and title restored to Plaintiffs.
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NOTICE OF PLAINTIFFS' MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT.
Case 2:09-cv-04589-AHM-AJW Document 123 Filed 09/13/10 Page 3 of 4 Page ID #:1136
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This Motion is based on this Notice of Motion and Motion and the accompany
Memorandum of Points and Authorities and Declarations, the Second Amended
Complaint, the Default by Court and other documents filed in this action, the matters
of which Plaintiffs requests the Court take judicial notice and upon such further
evidence and argument as may offered in support of the Motion.
DATED: I
Plaintiff
DATED: t '7--10
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NOTICE OF PLAINTIFFS' MOTION AND MOTION FOR ENTRY OF DEFAULT JUDGMENT.
Case 2:09-cv-04589-AHM-AJW Document 123 Filed 09/13/10 Page 4 of 4 Page ID #:1137
PROOF OF SERVICE
I am a citizen of the United States; I am over 18 years of age; my business address is 9353 Bolsa
Ave, #L4, Westminster, California 92683. I am employed in the County of Orange where this
mailing occurred.
On 09113/2010 , I served the following document(s):
PLAINTIFFS' MOTION FOR ENTRY OF DEFAULT JUDGMENT, POINT AUTHORITY IN
SUPPORT THEREOF.
By placing a true copy thereof enclosed in a sealed envelope and served in the manner described
below to each of the parties herein and addressed as follows:
ADORNO YOSS ALVARADO & SMITH
Attention S. Christopher Yoo
1 MacArthur Place, Suite 200
Santa Ana, CA 92707
WRIGHT, FINLAY & ZAK, LLP
Attention: T. Robert Finlay
4665 MacArthur Court, Suite 280
Newport Beach, CA 92660
xx BY MAIL: I caused such envelope(s) to be deposited in the mail at my business address,
addressed to the addressee(s) designated. It is deposited with the United States Postal Service on that
same day in the ordinary course of business.
BY HAND DELIVERY: I caused such envelope(s) to be delivered by hand to the
addressee(s) designated.
BY FEDERAL EXPRESS: I caused such envelope(s) to be delivered via Federal Express to
the addressee(s) designated.
BY FACSIMILE: I caused said documents(s) to be transmitted to the telephone number(s) of
the addressee(s) designated.
I declare under penalty of perjury under the laws of the United States of America that the foregoing
is true and correct.
Executed at Westminster, California, on 09/13/2010

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