Notice of Demurrer
Autor: mikel0411 • October 21, 2015 • Creative Writing • 3,516 Words (15 Pages) • 709 Views
MICHAEL M. LE, ESQ., SBN 255056
MICHAEL R. GONZALES., SBN 261302
BUCKELY MADOLE, P.C.
301 E. Ocean Drive, Suite# 1720
Long Beach, California 90802
Telephone: (562) 983-5363
Facsimile: (562) 983-5363
Email: michael.le@buckleymadole.com
Attorney for Defendant,
NBS DEFAULT SERVICES, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF MARIN
MARIN SUPERIOR COURT
MARTIN W. JOHNSON, an individual and as Trustee of the Johnson Family Trust; KATHLEEN A. UMREIN (incorrectly referred to as ‘Kathleen Umreir) an individual and as Trustee of the Johnson Family Trust Plaintiffs, vs. JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, a Delaware corporation; NBS DEFAULT SERVICES LLC, a Texas Limited Liability Company, doing business in California; All Persons Unknown, Claiming Lien or Interest in the Property Described in the Complaint Adverse to Plaintiffs’ Title, or Any Cloud on Plaintiffs’ Title thereto, and Does 1 THROUGH 20, INCLUSIVE Defendants. | CASE NO.: CIV1300049 DEFENDANT NBS DEFAULT SERVICES, LLC’S NOTICE OF DEMURRER AND DEMURRER TO FIRST AMENDED COMPLAINT; MEMORANDUM IN SUPPORT THERE OF Date: Time: Dept: Judge: Action filed: Trial Date: None set |
NOTICE OF DEMURRER
TO THE COURT, ALL INTERESTED PARTIES HEREIN, AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT a hearing will be held on ________, 2013 at _________
a.m./p.m. or as soon thereafter as the matter can be heard in Department ______ of the above entitled Court, located at 3501 Civic Center Drive, Room 113, San Rafael, California, 94903 on the within Demurrer of NBS Default Services, LLC (hereinafter “NBS”), to the First Amended Complaint (hereinafter “FAC”) filed by MARTIN W. JOHNSON and KATHLEEN UMREIN (“Plaintiffs”).
Hereinafter “DEMURRER DEFENDANT” refers to Defendants NBS.
Hereinafter “CCP” refers to the Code of Civil Procedure.
The Demurrer will be based on this Notice of Hearing, the accompanying Demurer and Memorandum of Points and Authorities, the Request for Judicial Notice filed concurrently herewith, the proposed order lodged herewith, and all pleadings and papers on file in the above-captioned action.
Date: June 28, 2013
______________________________
Michael M. Le, Esq. Attorneys for Defendant
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