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TIMOTHY L. MCCANDLESS, ESQ. SBN 147715 LAW OFFICES OF TIMOTHY L. MCCANDLESS 1881 Business Center Drive, Suite 9A San Bernardino, CA 92409 (909) 890-9192 Telephone (909) 382-9956 Facsimile Attorneys for Defendants, Michelle Cabesas and Leticia Edillo

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SOLANO SOLANO JUSTICE CENTER FANNIE MAE A/K/A FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff, vs. MICHELLE CABESAS AND LETICIA EDILLO, and DOES 1 through 10, Inclusive Defendant(s). Case No.: VCM106610 DEFENDANTS TRIAL BREIF

The Notice of Trustee Sale dated January 29, 2009 is without compliance statement that the beneficiary of beneficiarys agent has indicated that the requirements of California Civil Code Section 2923.5 have been met, simply attached the Declaration of Due Diligence that is required to be attached to the Notice of Default or Notice of Trustees Sale is improper pursuant to California Civil Code 2923.5, therefore making the Notice of Trustees Sale void. Also, the Notice of Default is defective, in violation of Civil
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Code section 2923.5, and therefore in violation of Civil Code section 2924, and thus renders the Trustees Deed upon which Plaintiff relies void, thus precluding relief to Plaintiff under Code of Civil Procedure subsection 1161a(b)(3). See Mabry V Superior Court decided June 2, 2010. Attached for the court convenience. To this brief The California Legislature passed Senate Bill 1137, impacting residential mortgage lenders, foreclosure procedures and eviction procedures. This law is effective immediately and extends on to January 1, 2013. The Statute amends provisions of the non judicial foreclosure procedures found in California Code of Civil Procedure Section 2924, by adding requirements for meetings, due diligence and notification of counseling. The primary purpose for the Statute I foreclosure procedures and imposes a unprecedented duty upon lenders relating to contact with borrowers. MEMORANDUM OF POINTS AND AUTHORITIES I. FACTUAL BACKGROUND The plaintiff, FANNIE MAE A/K/A FEDERAL NATIONAL MORTGAGE
ASSOCIATION, filed its unlawful detainer Complaint on or about August 4, 2009. The

Complaint at its paragraph 1 proceeds upon a Trustees Deed that was issued after foreclosure of a deed of trust. It stated that Plaintiffs title was duly perfected by Trustees Deed Upon sale recorded on July 8, 2009 as Instrument No. 09-57824 in the Office of the Solano County Recorder and that at his non judicial foreclosure sale was held in accordance with California Civil Code Sections 2924 et seq In response to this allegation, Defendant in her Answer at paragraph 1 denies that the power of extrajudicial sale was lawfully exercised. Defendant further specially denies any implied pleading that the foreclosure sale was duly conducted in compliance with all of the applicable requirements of the California Civil Code. Defendant admits that the Trustees Deed has been publicly recorded as alleged, but denies that the recording is valid. The validity of the Trustees Deed was thus fully joined as an issue.

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As noted just above, Defendants Answer at its paragraph 1 stated that Defendant generally and specifically denies each and every allegation in paragraph 1. The validity of the Notice of Default was thus fully joined as an issue. The subject Notice of Default and Election to Sell, filed on July 30, 2008, is presented in the Request for Judicial Notice In Support of Defendants Motion for Summary Judgment, which is filed concurrently herewith. The said Notice of Default clearly lacks any language as required by Civil Code section 2923.5(b), concerning attempt to contact the borrower about options for the borrower to avoid foreclosure. II. THE PLAINTIFF MUST PLEAD AND DEMONSTRATE ITS STRICT COMPLIANCE WITH THE STATUTES APPLICABLE TO A DISPOSSESSION OF PROPERTY. As a general rule of pleading, it is necessary to allege that there has been compliance with all provisions of statute. In pleading a right or privilege derived from statute, one must allege the facts required by the statute as the foundation of the right... The plaintiff must bring himself squarely and clearly within the terms of the statute on which he relies or must rely. .. If the statute is one by which another has been divested of property without his consent, the plaintiff must show that the statute has been strictly followed in every particular. 49 Cal.Jur.3d (1979 ed.), pages 457-458, Pleading at 81. It is for this reason that the courts in California have held, for a very long time, that a plaintiff in an unlawful detainer suit under Code of Civil Procedure section 1161a(b)(3) must plead and prove that the plaintiff obtained and perfected a valid title under a Trustees Deed. Title, to the extent that it has been duly perfected, thus becomes an issue, and the defendant may assert defenses relative thereto. 28 Cal.Jur.3d (Rev. 1978), page 362, Ejectment and Related Remedies at 130, citing, inter alia, Cruce v. Stein (1956), 146 Cal.App.2d 688, and Byrne v. Baker (1963), 221 Cal.App.2d 1. [Emphasis added.]

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Fully consistent with this general principle of pleading, just as section 1161a(b) creates a specific duty of giving a written notice to quit to an alleged holdover tenant (i.e., the former property owner), correlatively CCP subsection 1166(a)(5) requires that the Complaint [s]tate specifically the method used to serve the defendant with the notice or notices of termination upon which the complaint is based. In other words, the pleading of the mere legal conclusion of statutory compliance is not enough; the factual nature of the compliance with the statutes provision must be pleaded. The requirements of Civil Code section 2924 is necessarily read into the provisions of Code of Civil Procedure section 1161a(b)(3), upon which this unlawful detainer action proceeds. If, in conduct of a foreclosure, there has not been compliance with section 2924, then there has not been the occurrence of all of the elements which are required by Code of Civil Procedure section 1161a(b)(3). It is exactly analogous to the enforcement of sections 2924a, 2924b, 2924c, and so on, all of which are read into section 2924, as the factual circumstances may cause them to apply. Similarly, the Plaintiff must plead and prove the Plaintiffs compliance with the provisions of Civil Code section 2924 and its sibling statutes. Subsection 2924(a) requires the serving of the Notice of Default in terms of the content of the Notice. But Code of Civil Procedure section 2924b provides numerous details about the manner of the giving of the Notice of Default. So, too, does section 2923.5. It would seem obvious that one need not plead compliance with statutes that do not apply to the subject matter. For example, Section 2924e concerns written notice of delinquencies to junior lienholders. The plaintiffs compliance with this provision does not affect the Plaintiffs duties towards the trustor/ mortgagor, as far as the foreclosure process and resulting Trustees Deed are concerned; no one would contend that compliance with such statutes is required. But Section 2924 does apply, as does section 2924b, and as does Section 2923.5. There is no reason why compliance with the specific provisions of these sections ought not to be required to be alleged by the Plaintiff. Perhaps the court, in a suit brought under section 1161a(3), might determine that there is a pleading limit which the Plaintiff need not cross, and that the compliance
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with deeper layers of the applicable statute should be presumed and that the pleading of compliance should be implied. Such an approach is taken, for example, with the issue of the Plaintiffs capacity to sue; the pleading of the Plaintiffs capacity to sue is presumed, and the pleading burden falls upon the defendant to specially negatively plead the Plaintiffs lack of capacity to sue. But nonetheless, a plaintiffs lack of capacity to sue may be made out upon a special demurrer [see Code of Civil Procedure subsection 430.10(b)], and by extension, any other failure or invalidation of an implied element ought to be grounds for some kind of demurrer. A fortiori, it is available in a motion for summary judgment, a proceeding that may go outside of the pleadings and judicially noticeable facts. Accordingly, even if the Plaintiff is not required in this proceeding to affirmatively or expressly plead not only 1) that it, Plaintiff duly perfected its title, but also 2) that its titular predecessor-in-interest complied with Civil Code section 2924 and its sibling statutes when it conducted the foreclosure process, yet such noncompliance ought to be grounds for a demurrer, if it can be made out through attached exhibits or through judicially noticeable materials. And that is the alternative ground for the motion for summary judgment at hand. IV. UNDER RECENTLY ENACTED CIVIL CODE SECTION 2923.5, THE NOTICE OF DEFAULT MUST REVEAL WHETHER OR NOT THE 30-DAY WAITING PERIOD UNDER SUBSECTION 2923.5(a) HAS BEEN OBSERVED. A mortgagee, trustee, beneficiary, or authorized agent may not file a notice of default pursuant to Section 2924 until 30 days after initial contact is made as required by paragraph (2) or 30 days after satisfying the due diligence requirements as described in subdivision (g). Civil Code subsection 2923.5(a)(1). A notice of default filed pursuant to Section 2924 shall include a declaration that the mortgagee, beneficiary, or authorized agent has contacted the borrower, has tried with

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due diligence to contact the borrower as required by this section, or that no contact was required pursuant to subdivision (h). Civil Code section 2923.5(b). The Unlawful Detainer Complaint on file (through implied incorporation of publicly-recorded documents that are judicially noticeable) does not comport with the statutes. Further, even if the special declaration was not explicitly required by Civil Code subsection 2923.5(b), nonetheless Californias pleading law would require it: there is a pleading policy in California that, if the plaintiff has been prevented from complying with the statutory requirements, the facts on which he relies as an excuse must be pleaded. Kline v. San Francisco Unified School Dist., 40 Cal.App.2d 174, 104 P.2d 661, hearing denied by Supreme Court as reported in 40 Cal.App.2d 178. To the extent that it is foreseeable that the Notice of Default will become an expressly or impliedly incorporated attachment to the unlawful detainer complaint, then its content is foreseeable as content of a complaint, and therefore pleadings policy is applicable to it. The sad fact for Plaintiff is this: its trustee or servicing agent simply did not comply with the law, when it set the foreclosure process in motion without documenting its compliance with Civil Code Section 2923.5. As noted above, strict compliance is the policy when parties are to be dispossessed of property; the court is not to disregard this because it thinks that no one was really hurt, anymore than it can disregard the violation of a penal statute for a victimless crime. The intent of the Legislature must be obeyed and enforced, at least until it violates a constitution; that is not the case here. The court must enforce Civil Code section 2924, and thus its incorporated statute, Civil Code section 2923.5. V. DEFENDANTS DO NOT HAVE STANDING TO FORECLOSE The FORECLOSERS are simply not the right parties to bring a nonjudicial foreclosure. Who is the beneficiary? The foreclosing beneficiary must have a legal or

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equitable right, title or interest in the a foreclosure action. The servicers do what the beneficiary tells them to do. Of course, the current holder of the note and mortgage is always a party in interest in a foreclosure proceeding. A partys standing to foreclose, and a partys right to invoke the rights under California non-judicial foreclosure law, typically becomes an issue when the foreclosing entity was not properly assigned the note and mortgage, when the foreclosing entity is unable to establish an unbroken chain of transfers from prior note holders, or when the true holder of the loan is in doubt. (Lender who assigned away interest in property was not the proper party to file suit to foreclose a mortgage, affd without opinion, There is a clear break in the chain of the trust deed and the promissory note from MERS c/o ROBERT E. WEISS INCORPORATED, LEHMAN BROTHERS, and FANNIE MAE to the next beneficiary in line, whomever that is. In finding that the foreclosing parties had not established their rights to foreclose, the Court stated: To the extent a note and mortgage are no longer held or owned by the originating lender, a plaintiff must appropriately document the chain of ownership to demonstrate its legal status vis-a-vis the items at the time it files suit on this items. Appropriate documentation includes, but is not limited to, trust and/or assignment documents executed before the action was commenced, or both as circumstances may require. In re Foreclosure Actions (N.D. Ohio November 14, 2007) 2007 WL 43034554 at 1. VI. DEFENDANT HAVE NO STANDING TO FORECLOSE The power of the foreclosure trustee comes from the beneficiary. The beneficiary, upon a default, can demand that the trustee proceed to sell the securing property. Jones v. Sierra Verdugo Water Co. (2d Dist. 1923) 63 Cal. App. 254, 19 262; Arakelian v.
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Sears (3d Dist. 1921) 53 Cal. App. 646. Upon the initiation of the foreclosure process, the foreclosure trustee may require that the beneficiary deliver to the trustee the original note, the deed of trust, any assignment of the note, a statement of condition that describes the terms of the note or secured contract, the unpaid principal balance, the defaults by the trustor, and a written request that the trustee commence foreclosure. See, e.g., California Trust Co. v. Smead Inv. Co., (2d Dist. 1935) 6 Cal.App. 2d 432, 434-435. However, the foreclosure process and resulting sale is not necessarily invalid if the trustee has not received the original note, deed of trust or a statement of condition. R.G. Hamilton Corp. v. Corum (1933) 218 Cal. 92, 97; California Trust Co. v. Smead Inv. Co. (2d Dist. 1935) 6 Cal. App. 2d 432, 435. That said, the beneficiary is and was under an affirmative duty to provide this information to PLAINTIFF upon demand, which it never did despite being asked for these items. The question becomes, what authority or right does the beneficiary have to order the trustee to go to sale? What right do the DEFENDANTS have to foreclose upon the property of plaintiff on a note that was executed in favor of a totally separate entity. A Holder means a person in possession of a negotiable instrument that is payable to the bearer (i.e., the one holding the note) or to an identified person who is the person in possession. California Commercial Code 1-201(b)(21)(A). A Bearer means a person in possession of the negotiable instrument ... payable to the bearer or indorsed in blank. Negotiation means a transfer of possession ... of an instrument by a person other than the issuer [DEFENDANTS] to a person who thereby becomes its holder. Negotiation is the term used in Article 3 of the California Commercial Code to describe a
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post-issuance event. When a negotiable instrument is negotiated, it may be negotiated in several ways, depending on whether the note is made generally to bearer or to a specific person. Again, it is the original of the instrument which must be negotiated, not a photocopy or reproduction. Moving beyond the question of endorsements, there is the question as to the existence of the original of the promissory note. Nowhere has any beneficiary indicated stated that it has in its possession the original of the promissory note in its possession. As mentioned above, the beneficiary must be identified in the notice of default California Civil Code 2924c(b)(1), which it was not. As mentioned above, a copy of the original of the note with endorsements and modifications must be produced upon request. California Civil Code 2943(b)(34 (1). It has not been so produced. The case of Lloyd v. Lawrence elaborates on the requirement that a beneficiary must have possession of the original and indorsed promissory note. In a suit on negotiable instruments, the burden is initially on the parties suing on the instrument to show first that he is the holder of the instrument sued on. [Citation]. A holder is a person who is in possession of a document of title or an instrument or an investment security drawn, issued, or indorsed to him or to his order or to bearer or in blank. UCC Section 1201(20). The most obvious way for a holder to establish that he is a holder of instruments sued on, of course, is to produce the instruments in evidence. Lloyd v. Lawrence (5th Circuit 1973) 472 F.2d 313, 316. In a suit on a negotiable instrument, possession is in very real sense, ninetenths of the law. Possession establishes a prima facie case of ownership. [Citation.] Proof of possession by production of the instrument entitles the owner to recover on it unless the opposing party establishes a defense. [Citation.] On the other hand, if the banks cannot produce the instruments, they will lose the benefit of the presumption of ownership, and the case may very well be determined on that issue. Lloyd v. Lawrence (5th Circuit 1973) 472 F.2d 313, 317.
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In order to have the status of a holder, a party must have possession of the paper. A transferee of a note who has not yet acquired possession of the note is not the holder of the note and therefore does not have the holders right to receive payment of the note. Brown v. Continental Savings Association (5th Circuit 1994) Slip. Op. at 12, FN 13. VII. WHY FANNIE MAE and its agents, successors MUST ESTABLISH STANDING TO FORECLOSE California non-judicial foreclosure occurs entirely outside of the Court system. That is why there is a requirement of strict compliance with mandates of the non-judicial foreclosure statutes. The statutory requirements are intended to protect the trustor from a wrongful or unfair loss of his property, and a valid foreclosure by the private power of sale requires strict compliance with the requirements of the statute. It has been a cornerstone of foreclosure law that the statutory requirements, intending to protect the trustor from a wrongful or unfair loss of the property, must be complied with strictly. Miller & Starr, California Real Estate (3d ed.), Deeds of Trust 41 st and Mortgages, Chapter 10 10.182. Close does not count. California non-judicial foreclosure law is premised on honesty and integrity in the foreclosure process. It is based on honesty and integrity on the part of the foreclosing entities. For example, California Civil Code 2924c(b)(1) requires a statement in the notice of trustee sale of the past due payments plus permitted costs and expenses. Understood in this requirement is that this statement must be accurate. This requirement of accuracy, of course, was a requirement that had to be specifically reiterated as necessary when the foreclosing entities subsequently included
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fraudulent fees and charges. The same applies to the right to foreclose. California nonjudicial foreclosure law presumes honesty and integrity in the foreclosure process. It assumes that only the lawful beneficiary through its foreclosure trustee will initiate foreclosure proceedings upon a homeowner. It presumes that the other requirements of California law which pertain to the ownership of the promissory note and the execution of the trust deed will have been complied with. The foundation of the right to foreclose is the simultaneous creation of the promissory note and the deed of trust, and their continued marriage. The trust deed standing alone has no value. The promissory note standing alone is an unsecured debt, much like a credit card debt. As a result, these two instruments must be kept together at all times. Alliance Mortgage Co. v. Rothwell (1995) 10 Cal. 4th 1226, 45 1235; Goodfellow v. Goodfellow (1933) 219 Cal. 548, 554; Fleming v. Kagan (2d Dist.1961) 189 Cal. App. 2d 791, 796; Turner v. Gosden (1st Dist. 1932) 121 Cal. App.20, 22. An assignees authority to bring a foreclosure action is most often challenged when the note and mortgage were not properly assigned or the assignee is unable to produce the note. Before a foreclosure action can be maintained in a judicial foreclosure state, the foreclosing entity is often required to present the original note or account for its absence. The standing issue in non-judicial foreclosure states such as California nevertheless presents the same procedural concern that the party foreclosing the mortgage must be the proper party with authority to foreclose. In states such as California, which require that notice, advertisement, and other statutory presale conditions be satisfied by the holder of the mortgage, standing is effectively challenged by a lawsuit which, as in
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this case, raises the question of a procedural defect contesting the foreclosure and the right of the beneficiary (and servicer) to foreclose. Supporting this reasoning is the case In re Maisel48. In that case, the trustee for a securitization trust sought relief from an automatic stay granted to bankrupt debtors on the grounds that the debtors had failed to make regular monthly payments on their mortgage loan to the trust. The Court concluded that the trustee had no colorable claim to the mortgaged property because the related note and mortgage were made out to the originator and not the trust at the time the motion for relief was filed. The Court consequently denied the motion. Defendants argument that the foreclosure trustee has an independent right to non-judicially foreclose upon a persons property, without challenge, would enable the following scenario. Mr. Thief could retain the services of any foreclosure trustee (such as Recon Trust) to foreclose upon a persons home. When the foreclosure trustee initiates the non-judicial foreclosure by recording a notice of default and then the notice of trustee sale, claiming due whatever Mr. Thief demands, the logical consequence of defendants argument is that the homeowner/ property owner has absolutely no right to contest this foreclosure action or even challenge the amounts being demanded. Specifically, the homeowner has no right to demand proof (produce the original note) that Mr. Thief has a right to have the foreclosure trustee conduct an auction sale of his home. To require tender would further mean that the homeowner would have to pay Mr. Thief off before he could even come to court. Directly supporting the position of the plaintiff is the case of In re

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Hwang. In re Hwang (2008) 396 B.49 R. 757. This case is a thoughtful and carefully considered opinion, the first considered opinion issued on these issues in California. It discusses the exact same issues existent in this case. It discusses the need of the real party in interest to prosecute a foreclosure, and the need of the original of the promissory note and the reasons therefore. Plaintiffs request that this Court peruse this decision as it clearly adjudicates the very same issues of this matter, and does so articulately and concisely. If plaintiffs were to include the language of Hwang in its argument, it would be simply redundant to the reasoning contained within the case itself. VIII. IT IS TIME ADHERE TO THE NEW LAWS SENATE BILL 1137 Senate Bill 1137 was enacted into law as emergency legislation on July 8, 2008. That is when this law, and California Civil Code 2923.6, took effect. The public policy and the legislative purpose of Senate Bill 1137 must be pondered as it directly applies to this matter. California Senate Bill 1137, it added a number of provisions to the nonjudicial foreclosure process as set forth in California Civil Code 2924 et seq. SB1137 clearly articulated the public policy and the significant concern of California. Among the concerns expressed by the words of this enacted law are: (a) California is facing an unprecedented threat to its state economy and local economies because of skyrocketing residential property foreclosure rates in California. (b) High foreclosure rates have adversely affected property values in California, and will have even greater adverse consequences as foreclosure rates continue to
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rise. ... More foreclosures means less money for schools, public safety, and other key services. (d) It is essential to the economic health of California for the state to ameliorate the deleterious effects on the state economy and local economies and the California housing market that will result from the continued foreclosures of residential properties in unprecedented numbers by modifying the foreclosure process to require mortgagees, beneficiaries, or authorized agents to contact borrowers and explore options that could avoid foreclosure. [Emphasis mine.] (g) This act is necessary to avoid unnecessary foreclosures of residential properties and thereby provide stability to California's statewide and regional economies and housing market by requiring early contact and communications between mortgagees, beneficiaries, or authorized agents and specified borrowers to explore options that could avoid foreclosure and by facilitating the modification or restructuring of loans in appropriate circumstances. California Senate Bill 58 ll 1137. In order to require discussions between a borrower and a lender, California Civil Code 2923.6(b) mandates, It is the intent of the Legislature that the mortgagee, beneficiary, or authorized agent offer the borrower a loan modification or workout plan if such a modification or plan is consistent with its contractual or other authority. The law is clear. It was passed as emergency legislation in order to stop the tidal wave of foreclosures. Senate Bill 1137 was not focused on the financial well-being of the foreclosing entities, the FORECLOSERs. It is focused on the public policy and public benefit of stopping the current deluge of foreclosures. California Civil Code 2923.5(c) requires that DEFENDANTS declare in their notice of trustee sale their efforts to contact Defendants and engage in foreclosure/loss mitigation. Their boilerplate and brazen statement in their notice of trustee sale does not comply with Section 2923.5(c) . Their declaration essentially is, See the Notice of Default. Section 2923.5 requires a
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declaration, with details, not a merely generalized statement and a generalized deflection as the defendants have attempted to reduce this requirement to. California Civil Code 2015.5 defines a declaration as a statement under oath. Critical here is section 2015.5, which defines a declaration as a writing that is signed, dated, and certified as true under penalty of perjury. In addition, section 2015.5 specifies that a declaration must either reveal a "place of execution" within California, or recite that it is made under the laws of the State of California. The Notice of Default and the Notice of Trustee Sale contain none of the requirements of a declaration as mandated by California Civil Code 2015.5. Additionally, this boilerplated statement does not set forth any details of the lenders efforts to assess the borrowers financial situation and to explore options for the borrower to avoid foreclosure The beneficiary or his designated agent declares that it contacted the borrower, tried with due diligence to contact the borrower, as required as by Civil Code 2923.5, or the borrower has surrendered the property to the beneficiary or authorized agent, or is otherwise exempt from the requirements of 2923.5 This boilerplated statement does not even indicate who made any contacts pursuant to the Notice of Default and what was discussed. The beneficiary or his designated agent declares that it contacted the borrower, tried with due diligence to contact the borrower, as required as by Civil Code 2923.5, or the borrower has surrendered the property to the beneficiary or authorized agent, or is otherwise exempt from the requirements of 2923.5 This boilerplated statement does not comport to the requirements of the statute, nor to the legislative intent of requiring such a declaration. The beneficiary or his designated agent declares that it contacted the borrower, tried with due diligence to contact the borrower, as required as by Civil Code 2923.5, or the
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borrower has surrendered the property to the beneficiary or authorized agent, or is otherwise exempt from the requirements of 2923.5 Defendants did not enter into good faith discussions as required by California Civil Code 2923.6. The Notice of Trustee Sale declaration tells one nothing about the defendants efforts to comply with California Civil Code 2923.5 even though a declaration of compliance is required in the Notice of Trustee Sale. For these reasons alone, the notice of trustee sale is void. These failures and violation of law mandate a declaration that the foreclosure process does not meet the requirements of California non-judicial foreclosure law. This entire foreclosure is therefore invalid. These law violations further justify without question the granting of a preliminary injunction prohibiting any foreclosure sale scheduled based on the previously recorded notice of default and notice of trustee sale. The harm to PLAINTIFF is conclusive by law.

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CONCLUSION The facts are not in dispute: 1. The Notice of Default is wholly devoid of language of compliance with Civil Code section 2923.5, which expressly requires a declaration thereof. 2. Plaintiffs predecessor-in-interest did not comply with that law. 3. As a result, Plaintiffs title is facially void. Accordingly, the case should be decided in favor of defendant and Plaintiff should be forced to comply with the mandates of civil code 2923.5 . Respectfully submitted, DATED: June 1, 2010 ____________________________________ Timothy L. McCandless, Esq., for THE LAW OFFICES OF TIMOTHY MCCANDLESS Counsel for Defendant, MICHELLE CABESAS AND
LETICIA EDILLO

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