Professional Documents
Culture Documents
'
FILED
MARK D. LONERGAN
(State Bar NO. 143622)
mdl@severson.com
THOMAS N. ABBOTT
(State Bar No. 245568)
tna@severson.com
BRIAN
S.
Clerk
By
One Embarcadero
Center,
San Francisco, California Suite 2600
941
Telephone: (415) 398~3344
ll
3m
SUPERIOR COURT OF
CALIFORNIA
CIV 535902
Plaintiff,
DEFENDANTS
vs.
OF AMERICA,
NATIONAL
SUCCESSOR BY MERGER
TO LASALLE
BANK, NATIONAL
ASSOCIATION, AS
I
REPLY IN SUPP
COMPLAINT
I
Date:
Time:
Dept:
_
Action Filed:
Trial Date:
---cw.5,,02
ogiscr
nbiection
26
-=lllllll\\\\\\\\\lll\\l\ll\l _
55000, 1722/8168224. l
DEFENDANTS OBIECTION
AND RESPONSE TO
CIV 535902
PLAINTIFF S SUR-REPLY
IN SUPPORT OF D
TO PLAINTIFF S
EMURRER
SECOND AMENDED
C OMPLAIN T
s-n
MANANTANS (Plaintiff) Second Amended Complaint (SAC). This Court continued the
demurrer hearing to July 29, 2016 following an original hearing and oral argument in July 15,
2016.
In continuing the hearing, the Court did not ask the parties for additional brieng or oral
argument after the matter was submitted by all parties following oral argument. Nevertheless, in
a
procedurally improper attempt to inuence this Courts ruling, Plaintiff led a Sur-Reply related
to the demurrer which was received by Defendants on July 21, 2016. Plaintiff cites no procedural
rule allowing for a sur-reply, nor did the Court request additional brieng. Accordingly,
Defendants Object to the sur-reply this Court should disregard Plaintiffs improper sur-reply in its
NMNNNNNNNHHP'HHHHHI-lh
Yvanova Expressly Does Not Address the Allegations Set forth in Plaintiffs Second
Amended Complaint.
oowomawm~ooo\10\m4>ww~
Paragraph 60
Despite being paid for the full balance of the mortgage loan, the original lender [acting as
the securitization sponsor and seller] as well as the interim successor lender [securitization
depositor] committed a material breach of the governing securitization agreement(s) when
these parties failed to assign the mortgage (DOT) and the underlying Original Mortgage
Note to the Trustee of the REMIC MBS Trust on or before the trusts Closing Date.
The SAC unambiguously alleges that the foreclosure sale was void because of the
v.
(Glaski, (20l3) 218 Cal.App.4th 1079, 1094-1095.) In their brieng, Plaintiffs rely 0n the more
recent Yvanova case for the proposition that they have alleged a void sale. (Yvanova
careful reading
v.
New
of Yvanova illustrates
CIV 535902
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFF S SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFFS SECOND AMENDED COMPLAINT
55000.1722/8168124.1
the Court expressly declined to determine whether Plaintiffs Closing Date theory alleges facts
M
sufficient to render
this case.
The holding in Yvanonva was purposely and expressly limited in stating that borrowers
have standing to challenge assignments as void, but not as voidable. (Yvanova, supra, 62 Ca1.4th
\toxmhw
at 939.) Specically, and crucial to the analysis in this case, Yvanova expresses no opinion as to
11
Defendants cite the decision in Rajamz'n v. Deutsche Bank Nat. Trust C0. (2nd
Cir.2014) 757 F.3d 79 (Rajamin ), as a rebuke of Glaski. Rajamin 's expressed
disagreement with Glaski, however, was on the question *941 whether, under New
York law, an assignment to a securitized trust made after the trust's closing date is
void 01' merely voidable. (Rajamin, at p. 90.) As explained earlier, that question is
outside the scope of our review and we express no opinion as to Glaski 's
correctness on the point.
12_
(Emphasis added.) (Yvanova, supra, 62 Ca1.4th at 940-41.) Thus, reliance on Yvanova for
10
13
14',
15; B.
void
as
case is misplaced.
Yvanova
l6
Recognizing the Yvanova Couit expressly declined to determine whether the fact pattern
17
an assignment
19
Sarerbak Court addressed the issue. In doing so, it recognized Yvanova expressly offers no
20
opinion
21
after the trust's closing date is void or merely voidable. (Salerbak v. JPMorgan Chase Bank, N.A.
22
as to
follows:
23
24
25:
26
as
27
28
(Sarerbak, supra, 245 Cal.App.4th at 815.) Because the Court determined the assignment
CIV 535902
2
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFF S SECOND AMENDED COMPLAINT
55000.1722/8I68124.l
it concluded
as
(Id. at 815.)
The Saterbak Court also rejected Plaintiffs argument that the Homeowners
Bill of Rights
(HBOR) somehow salvages Plaintiffs Closing Date theory. However, Saterbak rejects this
argument for the same reasons Defendants point to it in their brieng that the assignment was
recorded prior to the enactment
\OOQ\IO\!I-b
11'
The FAC alleges the DOT was assigned on December 27, 201 1, and recorded on
December l7, 2012. Saterbak fails to point to any provision suggesting that the
California Legislature intended the HBOR to apply retroactively. (Myers v. Philip
Morris Companies, Inc. (2002) 28 Ca1.4th 828, 841, 123 Cal.Rptr.2d 40, 50 P.3d
751 [California courts comply with the legal principle that unless there is an
express retroactivity provision, a statute will not be applied retroactively unless it
is very clear from extrinsic sources that the Legislature
must have intended a
retroactive application ].) Therefore, the HBOR does not grant Saterbak new
rights on appeal.
l2
13
Thus, HBOR does not salvage Plaintiff s theory as alleged in the brieng.
10
III. CONCLUSION
14
15
Based on the foregoing, this Court should properly conclude that Plaintiff lacks standing to
.
16
challenge the assignment as it is voidable, not void, under the Closing Date theory set forth in
l7 the SAC. The Court should likewise conclude that the HBOR does not salvage this theory,
18
19
20
reply is properly disregarded by the Court. However, in the event the Court does consider the
21
brieng, the Court should also consider the arguments herein as a matter of fairness.
22
23
By:
7'):
Brian __S_."4<_I;/l_iittemore
24
25
26'
27'
28
CIV 535902
3
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFFS SECOND AMENDED COMPLAINT
55000.1722/8168l24.l
PROOF 0F SERVICE
Regina Manantan v. Wells Fargo Bank, N.A., et al.
San Mateo County Superior Court Case No. CIV 535902
At the time of service, I was over 18 years 0f age and not a party to this action. I am
employed in the County of San Francisco, State 0f California. My business address is One
Embarcadero Center, Suite 2600, San Francisco, CA 94111.
On July 25, 2016,
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I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
can.
(Cam
v
[\J
'
ChilarehQ, Kada
N
N
N
N
N
CIV 535902
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFFS SECOND AMENDED COMPLAINT
55000.1722/8168124.1
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limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss.Maximum for items of
extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our ServiceGuide. Written
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Warning: Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could
result in additional billing charges, along with the cancellation of your FedEx account number.
Use of thls system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com.FedEx
will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non-delivery,misdelivery,or
misinformation. unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim.Limitations
found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package. loss
of sales, income interest, prot, attorney's fees, costs, and other forms of damage whether direct, incidental,consequential, or special is
limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented Ioss.Maximum for items of
extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our ServiceGuide. Written
claims must be filed within strict time limits, see current FedEx Service Guide.
https://www.fedex.com/shipping/html/enPrintIFrame.htmi
7/25/2016
1ndl@severson.com
\14_o\
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10
REGINA MANANTAN,
Case No.
CIV 535902
14-
Plaintiff,
15
vs.
l6
WELLS FARGO BANK, N.A., D/B/A
AMERICAS SERVICING COMPANY, U.S.
BANK NATIONAL ASSOCIATION, AS
COMPLAINT
17
18
TRUSTEE, SUCCESSOR-TN-INTEREST TO
Time:
Dept.:
ASSOCIATION AS TRUSTEE,
SUCCESSOR BY MERGER TO LASALLE
BANK, NATIONAL ASSOCIATION, AS
TRUSTEE FOR MORGAN STANLEY
MORTGAGE LOAN TRUST 2007-7AX,
QUALITY LOAN SERVICE
CORPORATION, MOAB, INVESTMENT
GROUP, LLC, and DOES 1 through 50,
inclusive,
Date:
20
5
21
1
22
23
Action Filed:
Trial Date:
Defendants.
24
25
26,
27
28
CIV 535902
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFFS SECOND AMENDED COMPLAINT
55000,]722/81681241
MANANTANs (Plaintiff) Second Amended Complaint (SAC). This Court continued the
demurrer hearing to July 29, 2016 following an original hearing and oral argument in July 15,
2016.
In continuing the hearing, the Court did not ask the parties for additional brieng or oral
argument after the matter was submitted by all parties following oral argument. Nevertheless, in
a
procedurally improper attempt to inuence this Courts ruling, Plaintiff led a Sur-Reply related
to the demurrer which was received by Defendants on July 21, 2016. Plaintiff cites no procedural
rule allowing for a sur-reply, nor did the Court request additional brieng. Accordingly,
Defendants Object to the sur-reply this Court should disregard Plaintiffs improper sur-reply in its
'
reply, Defendants respectfully request that the Court likewise consider the arguments contained
herein.
Paragraph 60
of Plaintiffs SAC
1n
Plaintiffs
Second
following:
Despite being paid fol the full balance of the mortgage loan, the original lender [acting as
the securitization sponsor and seller] as well as the interim successor lender [securitization
depositor] committed a material bieach of the governing securitization agreement(s) when
these parties failed to assign the mortgage (DOT) and the underlying Original Mortgage
Note to the Trustee of the REMIC MBS Trust on or before the trust s Closing Date.
The SAC unambiguously alleges that the foreclosure sale was void because of the
v.
(Glaski, (2013) 218 Cal.App.4th 1079, 1094-1095.) In their brieng, Plaintiff s rely on the more
recent Yvanova case for the proposition .that they have alleged a void sale. (Yvanova
v.
New
Century Mortg. Corp. (2016) 62. Cal. 4th 919.) However, a careful reading of Yvanova illustrates
CIV 535902.
M
DEFENDANTS OBJECTION AND RESPONSE TO PLAIN IIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFF S SECOND AMENDED COMPLAINT
550001722/81681241
sufcient to render
ALAN
this case.
The holding in Yvanonva was purposely and expressly limited in stating that borrowers
have standing to challenge assignments as void, but not as voidable. (Yvanova, supra, 62 Cal.4th
\10\UI
at 939.) Specically, and crucial to the analysis in this case, Yvanova expresses no opinion as to
ll
Defendants cite the decision in Rajamin v. Deutsche Bank Nat. Trust C0. (2nd
Cir.2014) 757 F.3d 79 (Rajamin ), as a rebuke of Glaski. Rajamin 's expressed
disagreement with Glaski, however, was on the question *941 whether, under New
York law, an assignment to a securitized trust made after the trust's closing date is
void or merely voidable. (Rajamin, at p. 90.) As explained earlier, that question is
outside the scope of our review and we express no opinion as to Glaski 's
correctness on the point.
12
(Emphasis added.) (Yvanova, supra, 62 Cal.4th at 940411.) Thus, reliance on Yvanova for
10
13
the proposition that the assignment is void as Plaintiff does in this case is misplaced.
Yvanova
B.
l7
Recognizing the Yvanova Court expressly declined to determine whether the fact pattern
18
presented in
19
Saterbak Court addressed the issue. In doing so, it recognized Yvanova expressly offers no
20
opinion
21
after the trust's closing date is void or merely voidable. (Salerbak v. JPMorgan Chase Bank, NA.
as to whether,
24
25
26
as
follows:
27
28
(Saterbak, supra, 245 Cal.App.4th at 815.) Because the Court determined the assignment
CIV 535902
2
DEFENDANTS OBJECTION'AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OFDEMURRER
TO PLAINTIFF S SECOND AMENDED COMPLAINT
55000.1722/8168124.1
'
(1d. at
815.)
The Saterbak Court also rejected Plaintiffs argument that the Homeowners
Bill of Rights
(HBOR) somehow salvages Plaintiffs Closing Date theory. However, Saterbak rejects this
argument for the same reasons Defendants point to
recorded prior to the enactment
The FAC alleges the DOT was assigned on December 27, 2011, and recorded on
December 17, 2012. Saterbak fails to point to any provision suggesting that the
California Legislature intended the HBOR to apply retroactively. (Myers v. Philip
Morris Companies, Inc. (2002) 28 Cal.4th 828, 841, 123 Cal.Rptr.2d 40, 50 P.3d
751 [California courts comply with the legal principle that unless there is an
express retroactivity provision, a statute will not be applied retroactively unless it
is very clear from extrinsic sources that the Legislature
must have intended a
retroactive application ].) Therefore, the HBOR does not grant Saterbak new
rights on appeal.
(Saterbak, 245 Ca1.App.4th at 818.)
Thus, HBOR does not salvage Plaintiffs theory as alleged in the briefing.
III. CONCLUSION
Based on the foregoing, this Court should properly conclude that Plaintiff lacks standing to
J
it is voidable, not void, under the Closing Date theory set forth in
the SAC. The Court should likewise conclude that the HBOR does not salvage this theory,
reply is properly disregarded by the Court. However, in the event the Court does consider the
as a
matter of fairness.
$1.,
>
Brian S.,'Whittemore
CIV 535902
3
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFFS SECOND AMENDED COMPLAINT
55000.1722/8l68124J
PROOF OF SERVICE
Regina Manantan v; Wells Fargo Bank, N.A., et a].
San Mateo County Superior Court Case No. CIV 535902
,_i
At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of San Francisco, State of California. My business address is One
Embarcadero Center, Suite 2600, San Francisco, CA 94111.
On July 25, 2016,
\owooqosgn-bww
COMPLAINT
on the interested parties in this action as follows:
wwwlowwwww-_f._.,_-._H~._._
Mina,
[62M
V
ChilarenQ. Kada
CIV 535902
DEFENDANTS OBJECTION AND RESPONSE TO PLAINTIFFS SUR-REPLY IN SUPPORT OF DEMURRER
TO PLAINTIFF S SECOND AMENDED COMPLAINT
55000.1722/8168124.1
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Print button on this page to print your label to your laser or inkjet printer.
Warning: Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could
result in additional billing charges, along with the cancellation of your FedEx account number.
Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com.FedEx
will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non-delivery,misdelivery,or
misinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim.Limitations
found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss
of sales, income interest, prot, attorney's fees, costs, and other forms of damage whether direct, incidental,consequential, or special is
limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented toss.Maximum for items of
extraordinary value is $1.000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our ServiceGuide. Written
claims must be filed within strict time limits, see current FedEx Service Guide.
https ://www.fedex.com/shipping/html/en/fPrintIFrame.html
7/25/20 i 6
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shipment so that the barcode portion of the label can be read and scanned.
Warning: Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could
result in additional billing charges, along with the cancellation of your FedEx account number.
Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com.FedEx
will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non-delivery,misdelivery,or
misinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim.Limitations
found In the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, Including intrinsic value of the package, loss
of sales, income interest, prot, attorney's fees, costs, and other forms of damage whether direct, incidental,consequential, or special is
limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented lossMaxlmum for items of
extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our ServiceGuide. Written
claims must be filed within strict time limits, see current FedEx Service Guide.
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Warning: Use only the printed original label for shipping. Using a photocopy of this label for shipping purposes is fraudulent and could
result in additional billing charges. along with the cancellation of your FedEx account number.
Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide. available on fedex.com.FedEx
will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage. delay. non-delivery.misdelivery.or
misinformation. unless you declare a higher value, pay an additional charge. document your actual loss and tile a timely claim.Limitations
found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss. including intrinsic value of the package. loss
of sales. income interest, prot. attorney's fees. costs. and other forms of damage whether direct. incidental,consequential. or special is
limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss.Maximum for items of
extraordinary value is $1.000. e.g. jewelry. precious metals. negotiable instruments and other items listed in our ServiceGuide. Written
claims must be led within strict time limits. see current FedEx Service Guide.
https://www.fedex.com/shipping/html/enl/PrintiFramehtml
7/25/2016