- TEENA COLEBROOK
3940 South Broad Street, Suite 7258
San Luis Obispo, CA 93401
Phone: (310) 420-0508
Plaintiff in Pro Per
Attorneys for Defendants
TIMOTHY B. McGINITY and ALLEN MATKINS LECK
GAMBLE MALLORY & NATSIS LLP
| SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN LUIS OBISPO |
|
| MS. TEENA COLEBROOK,
Plaintiff, Vs. Defendants. |
Case No.: 21CV-0123
SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S DEMURRER AND ANTI SLAPP Judge Tana L. Coates Department 9 |
Plaintiff, MS. TEENA COLEBROOK, hereby requests the Court take judicial notice of the following exhibits pursuant to Evidence Code Sections 452 and 453, as appropriate, in support of Plaintiff’s Response to Defendant’s Demurrer and Anti SLAPP.
EXHIBIT A: Defendant’s 2016 letter. At the bottom of page 2, the Defendants admit to never having any intention to send what they promised.
EXHIBIT B: Defendant’s 2017 letter. In Section C of this letter, the Defendant stated that he will send the original documents.
EXHIBIT C: Affidavit of the broker who submitted Plaintiff’s offer to pay in 2013.
EXHIBIT D: California’s Tender Rule, pursuant to California Civil Code Section 2924c. CA Civ Code § 2924c (2017) (a) (1), et al.
EXHIBIT E: Defendants’ April 19, 2021 letter. This letter was only sent to Plaintiff. Therefore, Plaintiff would like this honorable court to see their admission of fraud.
EXHIBIT F: Plaintiff’s October 31, 2016 letter to Defendant McGinity.
EXHIBIT G: Plaintiff’s November 12, 2018 letter to Ellen Alemany, the CEO of CIT.
EXHIBIT H: Plaintiff’s complaint filed on February 16, 2021.
EXHIBIT I: United States of America ex rel. and Andrew Mitchell, and Andrew Mitchell, v. CIT Bank, N.A., d/b/a One West Bank, and CIT Group, Inc., NO. 4:14- cv-833.
EXHIBIT J: In the Matter of CIT GROUP, INC. Livingston, New Jersey, No. 17-046- CMP-HC. 2018 Consent Order on CIT-OWB. The Office of Thrift and Supervision (OTS) found out that the Association (OWB) is a servicer of mortgages not the owner. Further, the OTS observed that OWB services a portfolio of approximately $141 billion dollars in residential mortgage loans. During and in 2018 another consent order fined them the following The Board of Governors hereby assesses CIT, as a successor to IMB, a civil money penalty in the amount of $5,200,000 to be paid upon the execution of this Consent.
EXHIBIT K: One west bank/CIT has been sanctioned or shown to defraud and lie 2018A state court judge in Florida Miami-Dade Circuit Judge Pedro P. Echarte Jr sanctioned One West bank for “Frivolous” Foreclosure a bank which the California state attorney general’s consumer law section has accused of rampant foreclosure violations.
EXHIBIT L: In 2018 Five banks were sanctioned and will pay a combined $35.5 million. One of the banks was run by Treasury’s Mnuchin, OCCs Otting. One West Bank/CIT Bank Appearance of new and improved documents after borrower raised a legal challenge to authority to foreclose May 26, 2011 — Bk. No. 09-19263-PB13 RS, No. CNR-2. 05-26-2011. In re: Jessie M. Arizmendi, … The court issued an order to show cause why compensatory and coercive sanctions are not appropriate. … In re Farmer, 257 B.R. 556, 560.
EXHIBIT M: OTS Consent Order against OWB.
EXHIBIT N: April 13, 2011, Consent Order against One West Bank.
DATED:
Respectfully submitted,
Signature
____________________
- TEENA COLEBROOK
3940 South Broad Street, Suite 7258
San Luis Obispo, CA 93401
Phone: (310) 420-0508
In Pro Per
CERTIFICATE OF SERVICE
I hereby certify that on [ENTER DATE], copies of the foregoing document have been sent to all the Defendants in the following address:
ALLEN MATKINS LECK GAMBLE
MALLORY & NATSIS LLP
JEFFREY R. PATTERSON (BAR NO. 126148)
MATTHEW J. MARINO (BAR NO. 214440)
One America Plaza
600 West Broadway, 27th Floor
San Diego, California 92101-0903
Phone: (619) 233-1155
Fax: (619) 233-1158
E-Mail: jpatterson@allenmatkins.com
mmarino@allenmatkins.com
Signature
____________________
- TEENA COLEBROOK
3940 South Broad Street, Suite 7258
San Luis Obispo, CA 93401
Phone: (310) 420-0508
In Pro Per
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